Disabled and in Jail: The Disability Rights of Prisoners

How far reaching is the Americans with Disabilities Act? While it clearly requires public buildings to be accessible, what does that mean for Americans in public buildings like state prisons? The United States Supreme Court set a new precedent for this act, in the case of Goodman & United States v. Georgia. Through this landmark case, the Court ruled prisoners can sue for monetary damages if they are being discriminated against due to a disability.

Tony Goodman v. Georgia

Plaintiff Tony Goodman, a wheelchair bound paraplegic, was an inmate at the Georgia State Prison where he was confined to a 12 by 3 feet cell for 23 hours each day. The small confines of the cell made it difficult, if not impossible, for Goodman to turn in his chair. Further, his cell was not outfitted with accessible bathroom facilities. Goodman also claimed that prison officials failed to give him necessary medical care and made no attempt to include him in prison programs attended by mobile prisoners.

In his 1999 suit, Goodman claimed discrimination under Title II of the Americans with Disabilities Act, or the ADA. Title II of the ADA states that "no qualified individual with a disability shall...be excluded from participation in or be denied the benefits of the services, programs, or activities of a public entity." Georgia claimed sovereign immunity, meaning Goodman had no right to bring the suit. A district court agreed, granting summary judgment.

The Appeal

An appeal on behalf of Goodman to the 11th Circuit proved fruitless as the appellate court simply affirmed the prior court's summary judgment; Goodman couldn't sue Georgia. Basing its decision on the Supreme Court's decision in Board of Trustees of the University of Alabama v. Garrett, the court found that Goodman's request for money damages was not allowed under Title I of the ADA.

Supreme Court Review

The attorneys for Goodman argued for Supreme Court review. They claimed their case should be decided based on the tenets of the case of Tennessee v. Lane. In Lane, the Supreme Court found that under the ADA Congress had the right to override state immunity from suit. A disabled plaintiff was able to sue the state for making it impossible to attend court due to lack of handicapped accessible entries. While the case did deal with Title II of the ADA, the decision was a narrow one limited to accessibility of judicial process.

The Supreme Court ultimately granted plaintiff Goodman's petition to hear his case. The Court would decide whether or not Title II of the ADA enables state immunity for suits by prisoners with disabilities who claim discrimination by state owned and operated prisons. In prior decisions, the Court held that inmates are protected by the ADA - the issues that faced the Justices in Goodman were limited to whether or not an inmate could sue for compensation for pain and suffering. The Supreme Court found inmates could sue. In a unanimous decision, Justice Scalia wrote that the ADA can be applied to state prisons, as it includes such conduct challengeable under the 14th Amendment which forbids cruel and unusual punishment. Thus, the court held that Goodman can sue the state for money damages from discriminatory practices.

Accommodating Disabled Prisoners

The decision in the Goodman case may force American prisons, already strapped financially, to quicken their construction of handicap-accessible areas. The attorney for the Georgia State Corrections Department stated that all 2,000 disabled prisoners in the system have been accommodated (Goodman's suit focused on a four year period from 1995 to 1999) and that the issue is a moot one. However, advocates for disabled prisoners feel that threat of damages is the only way to insure that prisons comply with the ADA. Adding this muscle to the ADA makes the act even stronger and the lives of the disabled a little easier in every sphere of life, even prison.