April Cadena v. El Paso County
946 F.3d 717
| 5th Cir. | 2020Background
- Cadena arrested three days after right tibia surgery; intake records showed recent surgery and noted she used a wheelchair and could not bear weight.
- Jail staff initially took her wheelchair, provided crutches and pain meds, and later returned a wheelchair order; Cadena repeatedly requested a wheelchair and assistance with meal delivery.
- While forced to transport a meal tray on crutches despite prior instability and requests for help, Cadena fell, sustaining malalignment requiring surgery and later alleging lasting nerve damage.
- Cadena sued El Paso County under Title II of the ADA and the Rehabilitation Act (failure to provide reasonable accommodations) and under 42 U.S.C. § 1983 (Fourteenth Amendment deliberate indifference/conditions of confinement).
- The district court granted summary judgment to the County; the Fifth Circuit reversed the ADA dismissal (triable issues on intentional denial of accommodations) but affirmed dismissal of the § 1983 claim (no unconstitutional condition or deliberate indifference). Case remanded on the ADA claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether County violated Title II/Rehabilitation Act by failing to provide reasonable accommodations (wheelchair, modified food delivery, medical care) | County knowingly denied needed accommodations (wheelchair and modified meal procedure); crutches were ineffective and caused fall and injury | County provided medical judgment (crutches) and was not required to adopt plaintiff's preferred accommodation; ADA does not remedy mere negligent medical care | Reversed: triable fact issues exist whether the County intentionally denied reasonable accommodations and whether crutches failed to provide meaningful access |
| Whether plaintiff must show intentional discrimination (for compensatory damages) under ADA | Intentionality shown by staff taking wheelchair, denying wheelchair requests despite obvious need, and refusing to modify procedures after observing instability | County argues any delay/denial was medical judgment or negligence, not intentional discrimination | Court: jury could find intentional discrimination (more than negligence) given repeated refusals and evidence County had wheelchairs and knew of danger |
| Whether deference to treating physician’s medical judgment bars ADA claim | Plaintiff: mobility aids are accommodations distinct from medical treatment; medical staff had recommended wheelchair and records supported need | County: decision was a reasoned medical judgment about mobility aid, so ADA claim conflicts with medical care context | Court: County’s reliance on medical judgment was misplaced here — records and orders support that wheelchair was appropriate and denial could be an ADA violation |
| Whether § 1983/Fourteenth Amendment claim survives (conditions of confinement or episodic deliberate indifference) | Denial of mobility accommodations and forced policies (e.g., carrying trays) amounted to unconstitutional conditions and deliberate indifference causing serious harm | County: isolated incidents, routine medical decisions, prompt treatment after fall, and no pervasive policy or objectively deliberate indifference | Affirmed: evidence insufficient to show unconstitutional pervasive condition or the high deliberate-indifference standard for episodic act against municipality |
Key Cases Cited
- Pennsylvania Dep’t of Corr. v. Yeskey, 524 U.S. 206 (1998) (prisons are public entities subject to Title II)
- United States v. Georgia, 546 U.S. 151 (2006) (refusal to accommodate mobility can deny benefits of prison services)
- Delano-Pyle v. Victoria Cty., 302 F.3d 567 (5th Cir. 2002) (intentional refusal to adapt communication supports ADA violation)
- Frame v. City of Arlington, 657 F.3d 215 (5th Cir. 2011) (public entities must make reasonable accommodations for mobility-impaired individuals)
- Alexander v. Choate, 469 U.S. 287 (1985) (reasonable accommodations must provide meaningful access)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standard — judge determines existence of genuine issue)
- Bell v. Wolfish, 441 U.S. 520 (1979) (conditions-of-confinement test for detainees)
- Hare v. City of Corinth, 74 F.3d 633 (5th Cir. 1996) (framework for episodic-act vs. conditions claims by pretrial detainees)
- Gobert v. Caldwell, 463 F.3d 339 (5th Cir. 2006) (definition of serious medical need and deliberate indifference standard)
- Duvall v. Dallas Cty., 631 F.3d 203 (5th Cir. 2011) (showing pervasive practice needed for conditions-of-confinement municipal liability)
- Bd. of County Comm’rs v. Brown, 520 U.S. 397 (1997) (municipal liability requires a policy or widespread practice constituting deliberate indifference)