Case: DOJ Investigation of Oklahoma's Mobile ID Application

This was an investigation about the accessibility of mobile applications under the Americans with Disabilities Act (ADA). The United States Department of Justice (DOJ) Civil Rights Division investigated Service Oklahoma under Title II of the ADA in response to a complaint alleging that Service Oklahoma's mobile application, the Oklahoma Mobile ID Application, was inaccessible to individuals with vision disabilities. The DOJ issued a Letter of Findings on November 16, 2023, and concluded that the application was inaccessible to individuals with vision disabilities, thus violating Title II of the ADA.

Service Oklahoma's Oklahoma Mobile ID application offered a digital version of a physical driver's license or other state-issued ID, but the DOJ concluded that it was inaccessible to individuals with disabilities, particularly those with vision impairments. The DOJ initiated this investigation following a complaint from an individual who could not use the application due to its lack of accessible features. This individual previously contacted the Oklahoma Department of Public Safety, Service Oklahoma's predecessor, to address these accessibility issues, and only escalated the complaint to the DOJ after no corrective actions were taken.

During the investigation, the DOJ reviewed user experiences and conducted its own accessibility testing. The application required users to perform tasks such as photographing an ID and taking a self-portrait through an interface that relied on visual cues, which were not accessible to users who were blind or had severe vision impairments. This lack of accommodation prevented these individuals from completing the registration process, thereby denying them the same services available to others. Thus, the continued inaccessibility of the OK Mobile ID App violated Title II of the ADA by failing to provide equal access and effective communication for users with vision disabilities.

To rectify the situation, the DOJ outlined several remedial measures that Service Oklahoma was required to implement. These included ensuring the application met or exceeded the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA standards, developing processes to regularly assess compliance and handle feedback regarding accessibility, and maintaining a public commitment to non-discrimination on their digital platforms. Service Oklahoma was also required to appoint an ADA Coordinator to oversee compliance and handle disability-related grievances effectively.

Lastly, the DOJ sought to work cooperatively with Service Oklahoma to address and resolve these violations. Still, if Service Oklahoma failed to engage in voluntary compliance negotiations or if such negotiations did not result in an acceptable outcome, the ROJ retained the right to pursue legal enforcement to ensure compliance with the ADA.