Pennsylvania Department of Corrections v. Yeskey

Supreme Court of the United States
141 L. Ed. 2d 215, 1998 U.S. LEXIS 3888, 524 U.S. 206 (1998)

ELI5:

Rule of Law:

Title II of the Americans with Disabilities Act of 1990 (ADA) unambiguously applies to inmates in state prisons, prohibiting discrimination on the basis of disability in the programs, services, and activities offered by correctional facilities.

Facts:

Ronald Yeskey was an inmate in a Pennsylvania correctional facility.
The sentencing court recommended that Yeskey be placed in Pennsylvania’s Motivational Boot Camp, a program for first-time offenders.
Successful completion of the Boot Camp program would have allowed Yeskey to be released on parole in six months.
Yeskey was denied admission to the Boot Camp program because of his medical history of hypertension.

Procedural Posture:

Ronald Yeskey sued the Pennsylvania Department of Corrections and several officials in the U.S. District Court, alleging a violation of the ADA.
The District Court dismissed the complaint for failure to state a claim, holding that the ADA does not apply to inmates in state prisons.
Yeskey (appellant) appealed to the U.S. Court of Appeals for the Third Circuit.
The Third Circuit reversed the District Court's dismissal, holding that the ADA does cover state inmates.
The Pennsylvania Department of Corrections (petitioners) petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.

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Issue:

Does Title II of the Americans with Disabilities Act of 1990, which prohibits discrimination by a 'public entity' against a 'qualified individual with a disability,' apply to inmates held in state prisons?

Opinions:

Majority - Justice Scalia

Yes. Title II of the Americans with Disabilities Act of 1990 unambiguously applies to inmates in state prisons. The Court reasoned that the plain language of the statute is not ambiguous. State prisons fall squarely within the ADA's definition of a 'public entity,' which includes any 'department' or 'instrumentality of a State.' The Court rejected the argument that prison programs are not 'benefits' or 'services,' noting that modern prisons provide many programs, services, and activities, including the very Boot Camp program at issue. The Court also dismissed the claim that prisoners are not 'qualified individuals' because their confinement is involuntary, explaining that the statutory terms 'eligibility' and 'participation' do not necessarily connote voluntariness and, in any event, participation in many prison programs like the Boot Camp is voluntary. Because the statutory text is unambiguous, its plain meaning governs, regardless of whether Congress specifically envisioned this application.

Analysis:

This unanimous decision significantly expanded the reach of the ADA by confirming that its protections extend into the state prison system, an area traditionally under state control. The ruling established that inmates with disabilities can bring claims for discrimination if they are denied access to prison programs, services, or activities, such as educational classes, vocational training, or rehabilitative programs. While the Court affirmed the statute's applicability, it deliberately left open the broader constitutional question of whether Congress had the authority to impose the ADA on state prisons under the Commerce Clause or the Fourteenth Amendment. This left the door open for future constitutional challenges to the law's application in this context.

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