Inmate wins ADA appeal arising from slip and fall in his cell

This disability discrimination case was filed by an inmate in Connecticut who alleges that the jail failed to stop a plumbing leakage in his cell, causing him to slip and fall on the water, exacerbating his preexisting injuries. The district court rejected the case upon finding plaintiff cannot show the injuries resulted from discriminatory intent. That's not how the Court of Appeals sees it, so the case returns to the district court for additional rulings.

The case is Sanchez v. Butricks, a summary order issued on June 10. Plaintiff is disabled and walks with a cane. In reasonable accommodation cases like this one, the plaintiff has to show the following:

When assessing a reasonable accommodation claim, we ask if the plaintiff, “‘as a practical matter[,]’ was denied ‘meaningful access’ to services, programs or activities to which he or she was ‘legally entitled.’” Hamilton v. Westchester County, 3 F.4th 86, 91 (2d Cir. 2021) (quoting Wright v. N.Y. State Dep’t of Corr., 831 F.3d 64, 72 (2d Cir. 2016)). There is no requirement that the plaintiff show discriminatory intent to make out a reasonable accommodation claim.

Looking at the case from that angle, plaintiff has a better shot at victory. The Second Circuit says plaintiff may have a case. "Sanchez specifically alleged that he told the maintenance supervisor and Defendant Rodriguez about the leak and requested it be fixed on April 27, 2020, over two weeks before his fall on May 15th." As it happens, Rodriguez claims he “was transferred out of [Sanchez’s] unit at or near April 24, 2020,” and had no “further interaction with Sanchez.” But Sanchez disputes this factual assertion. That brings us to basic summary judgment principles. "If a jury were to credit Sanchez over Rodriguez, it could find that a prison official was aware of the dangerous leak a full eighteen days before Sanchez fell and injured himself."

But we have another problem: the Eleventh Amendment, which prevents you from suing the state for certain statutory violations. Cases hold that Title II violations under the Americans with Disabilities Act cannot be enforced against the state. Defendants did not assert this argument in the district court. They raise this issue on appeal, however. This is a complex area of the law. The Second Circuit notes that while it has held in the past that plaintiffs in Title II cases must show the violation was motivated by discriminatory intent, or ill-will because of the plaintiff's disability, that rule only applies to Title II violations that also violate the Equal Protection Clause. But Title II plaintiffs may argue that their violations are premised upon other Fourteenth Amendment rights. Plaintiff argues this exception applies to him because the Fourteenth Amendment protects prisoners who rely on public entities for basic services. 

As you can see, this issue is complex. Since the district court did not analyze the issues set forth above under the Eleventh Amendment, the case is remanded for the trial court to deal with all of this in the first instance.