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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