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Sixth Circuit: Shy Bladder Suit Returned to District Court
The U.S. Court of Appeals for the Sixth Circuit affirmed in part and reversed in part the dismissal of a prisoner’s lawsuit alleging violations under 42 U.S.C. § 1983 and the Americans with Disabilities Act (ADA).
Danny Ray Meeks, a Tennessee prisoner, sued the Tennessee Department of Corrections (TDOC) and seven TDOC employees after being twice disciplined for failing to give a urine sample during drug tests. Meeks claimed that he suffered from pauresis, the clinical term for “shy bladder syndrome,” a medical condition that makes it difficult for some two million Americans to urinate in front of others.
In an unpublished per curiam opinion, the Court of Appeals affirmed the dismissal of Meeks’ § 1983 claims because he had failed to get the two disciplinary convictions overturned. A favorable ruling on Meeks’ claims, the appellate court wrote, “would imply the invalidity of his conviction or the length of his sentence,” citing Edwards v. Balisok, 520 U.S. 641 (1997) [PLN, July 1997, p.1].
The Sixth Circuit concluded, however, that a remand was necessary to determine whether Meeks was entitled to an injunction under the ADA. The district court had held that Meeks failed to allege he was excluded from any program or benefits in violation of the ADA.
However, the Court of Appeals decided that Meeks’ allegations that the TDOC discriminated against him by “denying him lower security classification, the right to work as a legal clerk, participation in the Arts & Crafts program, visitation, and the ability to purchase packages as a result of his disciplinary convictions” was sufficient to allege a claim under the ADA.
Accordingly, the case was remanded to the district court for further consideration of Meeks’ ADA claim. See: Meeks v. Tennessee Department of Corrections, Case No. 08-05980 (6th Cir. 2009) (unpublished).
This case remains pending before the district court on cross-motions for summary judgment. See: Meeks v. Tennessee Department of Corrections, U.S.D.C. (M.D. Tenn.), Case No. 1:07-cv-00013.
Danny Ray Meeks, a Tennessee prisoner, sued the Tennessee Department of Corrections (TDOC) and seven TDOC employees after being twice disciplined for failing to give a urine sample during drug tests. Meeks claimed that he suffered from pauresis, the clinical term for “shy bladder syndrome,” a medical condition that makes it difficult for some two million Americans to urinate in front of others.
In an unpublished per curiam opinion, the Court of Appeals affirmed the dismissal of Meeks’ § 1983 claims because he had failed to get the two disciplinary convictions overturned. A favorable ruling on Meeks’ claims, the appellate court wrote, “would imply the invalidity of his conviction or the length of his sentence,” citing Edwards v. Balisok, 520 U.S. 641 (1997) [PLN, July 1997, p.1].
The Sixth Circuit concluded, however, that a remand was necessary to determine whether Meeks was entitled to an injunction under the ADA. The district court had held that Meeks failed to allege he was excluded from any program or benefits in violation of the ADA.
However, the Court of Appeals decided that Meeks’ allegations that the TDOC discriminated against him by “denying him lower security classification, the right to work as a legal clerk, participation in the Arts & Crafts program, visitation, and the ability to purchase packages as a result of his disciplinary convictions” was sufficient to allege a claim under the ADA.
Accordingly, the case was remanded to the district court for further consideration of Meeks’ ADA claim. See: Meeks v. Tennessee Department of Corrections, Case No. 08-05980 (6th Cir. 2009) (unpublished).
This case remains pending before the district court on cross-motions for summary judgment. See: Meeks v. Tennessee Department of Corrections, U.S.D.C. (M.D. Tenn.), Case No. 1:07-cv-00013.
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Related legal cases
Meeks v. Tennessee Department of Corrections
| Year | 2010 |
|---|---|
| Cite | U.S.D.C. (M.D. Tenn.), Case No. 1:07-cv-00013 |
| Level | District Court |
| Injunction Status | N/A |
Meeks v. Tennessee Department of Corrections
| Year | 2009 |
|---|---|
| Cite | Case No. 08-05980 (6th Cir. 2009) |
| Level | Court of Appeals |
| Injunction Status | N/A |