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Dismissal of Massachusetts Prisoner's ADA/RA Claims Reversed

The Massachusetts Supreme Judicial Court reversed the dismissal of a prisoner's claim that prison officials failed to provide reasonable accommodation for his disability.

Massachusetts prisoner Paul Shedlock suffers "a constellation of medical problems, including sciatica, degenerative joint disease, and left leg atrophy." He "regularly suffers pain in his neck, shoulder, back, hip, knee, and ankle" and he "has developed a 'severe antalgic gait,' a limp adopted to minimize pain." Shedlock has used a cane since 1992.

In 1997, prison officials attempted to house Shedlock on upper tiers despite a medical order that he be confined to bottom tier cells. When he objected, a guard said the prison does not "cater to cripples." When Shedlock refused to go to his new cell, he was issued a misconduct report and segregated. Once released from segregation, guards again assigned Shedlock to upper tier housing.

On July 15, 1998, Shedlock brought a state court action, alleging that prison officials failed to provide adequate accommodation for his disability and retaliated against him for asserting a right to such accommodation. The district court granted prison officials summary judgment.

The Supreme Judicial Court reversed, in part, concluding "that Shedlock has presented sufficient evidence to permit the finder of fact to conclude that he is a disabled or handicapped person within the meaning of the" Americans with Disabilities Act, (ADA), the Rehabilitation Act and the Massachusetts Constitution. "Having obtained the requisite medical confirmation of his need for a first-floor cell," the court found that "transferring Shedlock to cells on higher floors could be found to be a denial of reasonable accommodation."

The court affirmed the dismissal of Shedlock's retaliation claim under the ADA, for conduct occurring between December 1997 and June 3, 1998, finding that defendants were entitled to qualified immunity on that claim because it was not clearly established that the ADA applies to prisoners until the Supreme Court's June 15, 1998 decision in Pennsylvania Department of Corrections v. Yeskey, 524 U.S. 206, 118 S.Ct 1952 (1998). See: Shedlock v. Department of Correction, 442 Mass. 844, 818 NE2d 1022 (Mass. 2004).

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Related legal case

Shedlock v. Department of Correction