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Case Name Hall v. Thomas PC-TX-0012
Docket / Court 4:97-cv-00874 ( S.D. Tex. )
State/Territory Texas
Case Type(s) Disability Rights-Pub. Accom.
Prison Conditions
Case Summary
On March 18, 1997, a federal inmate in state custody in Texas filed a lawsuit under 42 U.S.C. § 1983 and the Americans with Disabilities Act, 42 U.S.C. § 12111 et seq in the United States District Court for the Southern District of Texas, Houston Division. The plaintiff, represented by private ... read more >
On March 18, 1997, a federal inmate in state custody in Texas filed a lawsuit under 42 U.S.C. § 1983 and the Americans with Disabilities Act, 42 U.S.C. § 12111 et seq in the United States District Court for the Southern District of Texas, Houston Division. The plaintiff, represented by private counsel, asked the court for declaratory relief, injunctive relief and monetary damages, claiming that the defendants had exhibited a deliberative indifference to his medical condition and as such had violated his constitutional and statutory rights. Specifically, the Plaintiff claimed that when he entered the custody of the Defendants his initial medical screening health questionnaire was incorrectly completed in violation of policy. The Plaintiff asserted that as a result of the indifferent administration of the initial medical screening health questionnaire, he was incorrectly classified as not disabled which prevented him from receiving the accommodations he required. Plaintiff in fact has epilepsy, major depression, and a number of other disabling disorders. The Plaintiff was subsequently housed in the administrative segregation section, rather than in the hospital ward as he claimed was required by his medical condition. The Plaintiff contends that this initial misclassification upon entry into custody lead to 17 months of being housed in an incorrect unit without access to the proper accommodations he was entitled to as a disabled person. The Plaintiff claimed that the lack of proper accommodations led to excessive seizures and mental anguish. Furthermore, the Plaintiff claimed that the Defendants had been deliberately indifferent to his medical condition and failed to adequately treat the Plaintiff's chronic kidney disorder for 17 months, which had serious implications for his health in violation of the equal protection clause and the due process clause. Additionally, the Plaintiff claimed that the Defendants had breached their duty owed to the Plaintiff as a disabled person by compelling him to wear leg irons, despite their use having been restricted because of his orthopedic disability. Furthermore, the Plaintiff claimed that the defendants had failed to provide him with appropriate medical care to control his diabetes, which led to a partial loss of his vision. The Plaintiff further contended that as a result of his inadequate medical care and incorrect classification, he stood trial for a federal crime in a diminished mental and debilitative state in violation of his 5th, 6th, 8th and 14th Amendment rights.

On motion for summary judgment, the District Court first found that Congress did not intend for the Americans with Disabilities Act to apply to the treatment of prisoners within state prisons. Furthermore, the District Court found that the Defendants were entitled to qualified immunity as to the Plaintiff's ADA claim. Pursuant to the 11th Amendment, the District Court dismissed all of the Plaintiff's claims for damages against Defendants in their official capacities. On the Plaintiff's deprivation of medical care claims, the court held that o amount a constitutional deprivation of medical care, the acts or omissions must be "sufficiently serious to evidence deliberate indifference to serious medical needs." Negligent failure to supply medical care does not amount to a constitutional deprivation. Consequently, as to the Plaintiff's §1983 claims, the District Court held that Hall was not denied medical care and consistently received medical care throughout his incarceration, therefore even taken as true, the Defendant's acts and omissions did not amount to a constitutional deprivation of medical care. Therefore, the Plaintiff's §1983 claims were dismissed by the District Court. In the end, the District Court granted all of the summary judgment motions before it, and dismissed a number of claims for failure to state a claim.

On appeal to the 5th Circuit Court of Appeals, the Plaintiff argued that the District Court incorrectly granted the motions for summary judgment and the dismissals for failure to state a claim. On October 26, 1999, the 5th Circuit affirmed the District Court's orders but also held that the District Court had erred in holding that the ADA does not apply to prisoners incarcerated in state prisons. Nevertheless, though it held that the ADA applies to the Plaintiff while incarcerated in the County Jail, the 5th Circuit upheld the District Court's decision on grounds of qualified immunity because the Plaintiff failed to show that the Defendants had shown a deliberate indifference to his serious medical need.

Justin Benson - 04/13/2011


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Issues and Causes of Action
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Issues
Discrimination-basis
Disability (inc. reasonable accommodations)
General
Restraints : physical
Medical/Mental Health
Medical care, general
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12111 et seq.
42 U.S.C. § 1983
Defendant(s) Sheriff Tommy B. Thomas
Plaintiff Description Federal inmate being detained in a county jail
Indexed Lawyer Organizations None on record
Class action status sought No
Class action status granted No
Prevailing Party Defendant
Public Int. Lawyer No
Nature of Relief None
Source of Relief None
Form of Settlement None on record
Order Duration not on record
Case Closing Year 1999
Case Ongoing No
Additional Resources
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Case Studies Civil Rights Injunctions Over Time: A Case Study of Jail and Prison Court Orders
N.Y.U. Law Review
By: Margo Schlanger (Washington University)
Citation: 81 N.Y.U. L. Rev. 550 (2006)
[ Detail ] [ PDF ] [ External Link ]

  Judicial Policy Making and the Modern State: How the Courts Reformed America's Prisons
By: Malcolm M. Feeley & Edward Rubin (UC Berkeley Boalt Hall School of Law & Vanderbilt School of Law Faculty)
Citation: (1998)
[ Detail ]

Docket(s)
4:97−cv−00874 (S.D. Tex.) 03/18/1997
PC-TX-0012-9000.pdf | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Plaintiff's Original Complaint 03/18/1997
PC-TX-0012-0001.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Motion for Summary Judgment of Major Michael Quinn In his Individual Capacity 08/28/1997
PC-TX-0012-0003.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Motion for Summary Judgment of Sheriff Tommy B. Thomas in his Individual Capacity 08/29/1997
PC-TX-0012-0004.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Defendants Seale, Guice, Trinh, Phi, Luu, Chassay, and Klein's Motion for Summary Judgment and Brief in Support 10/10/1997
PC-TX-0012-0005.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Memorandum Opinion 01/16/1998 (1998 WL 404386) (S.D. Tex.)
PC-TX-0012-0006.pdf | WESTLAW | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Brief of Appellant 09/04/1998 (1998 WL 34085768)
PC-TX-0012-0007.pdf | WESTLAW | Detail
Document Source: Westlaw
Defendant-Appellee's Letter Brief 10/06/1998 (1998 WL 34085767)
PC-TX-0012-0008.pdf | WESTLAW | Detail
Document Source: Westlaw
Appeal from the United States District Court for the Southern District of Texas 09/29/1999 (190 F.3d 693)
PC-TX-0012-0002.pdf | WESTLAW| LEXIS | Detail
Judges Benavides, Fortunato Pedro (Fifth Circuit)
PC-TX-0012-0002
DeMoss, Harold R. Jr. (Fifth Circuit)
PC-TX-0012-0002
Hoyt, Kenneth M. (S.D. Tex.)
PC-TX-0012-0006 | PC-TX-0012-9000
Politz, Henry Anthony (Fifth Circuit)
PC-TX-0012-0002
Monitors/Masters None on record
Plaintiff's Lawyers Bevans, Thomas J (Texas)
PC-TX-0012-0001 | PC-TX-0012-9000
Defendant's Lawyers Baker, Mary E (Texas)
PC-TX-0012-0003 | PC-TX-0012-0004 | PC-TX-0012-9000
Durham, Drew Taylor (Texas)
PC-TX-0012-0005 | PC-TX-0012-0008
Fleming, Michael P (Texas)
PC-TX-0012-0003 | PC-TX-0012-0004
Kraatz, Ann (Texas)
PC-TX-0012-0005 | PC-TX-0012-0008
Longmire, Ralph C (Texas)
PC-TX-0012-0005 | PC-TX-0012-0008 | PC-TX-0012-9000
Morales, Dan (Texas)
PC-TX-0012-0005 | PC-TX-0012-0008
Vega, Jorge (Texas)
PC-TX-0012-0005 | PC-TX-0012-0008
Other Lawyers None on record

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