ADA Claim

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7^th Circuit Court of Appeals

Case Name: Lee A. Brown v. Michael Meisner, et al

Case No.: 22-2458

Officials: Wood, Hamilton, and Kirsch, Circuit Judges.

Focus: ADA Claim

Brown injured his knee when he fell while at his former prison, leading to the need for medical attention and placement in the “special needs” category. This special arrangement included provisions such as a lower bunk, wheelchair, and crutches. Despite this, when Brown was transferred weeks later, he found himself spending initial months in segregation. During this time, he repeatedly requested medical assistance, which unfortunately went unaddressed. Subsequently, Brown was moved to a shared cell where his cellmate, also disabled, occupied the lower bunk. While attempting to reach his top bunk, Brown had another fall.

After this incident, Brown consulted a doctor who advised him to undergo surgery. However, the prison administration declined to provide the necessary surgical intervention. In response, Brown reached out to the prison’s “special needs committee” and submitted an ADA reasonable accommodation request. He also raised concerns about potential violations of his Eighth Amendment rights. Despite these efforts, the district court dismissed his case.

However, the Seventh Circuit took a different stance and partially reversed the decision. They recognized that Brown had presented a valid failure-to-accommodate claim under 42 U.S.C. 12132. It was emphasized that Brown’s complaint wasn’t required to specify a particular legal theory or encompass all the legal elements of a specific claim. His knee injury qualified as a disability under the ADA, and he had asserted a failure to accommodate this disability. Importantly, there was no legal mandate for Brown to pinpoint a specific accommodation in his initial complaint.

While acknowledging that the ADA doesn’t pertain to matters of medical malpractice, it was highlighted that Brown’s grievance wasn’t about substandard medical care.

Affirmed in part, vacated in part, and remanded.

Decided 08/25/23

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