974 F.3d 263
3rd Cir.2020Background
- Craig Geness, a permanently mentally disabled man, was arrested in 2006 on a homicide-related charge and was repeatedly found incompetent to stand trial.
- Orders for psychiatric evaluation and transfer were delayed or not implemented; Geness spent roughly nine years in custody and civil commitment before the Commonwealth nolle prossed the charges in 2015.
- Geness sued multiple defendants, later amending to assert Title II of the ADA and Fourteenth Amendment claims against the Commonwealth, the Administrative Office of Pennsylvania Courts (AOPC), and the Department of Human Services (DHS).
- The District Court permitted the Title II/Fourteenth Amendment claim against AOPC to proceed, rejecting AOPC’s sovereign-immunity defense; AOPC appealed that denial.
- The Third Circuit majority reversed, holding Geness failed to plead a plausible Title II claim against AOPC and therefore that AOPC retains Eleventh Amendment immunity; a dissent would have affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether AOPC is subject to suit under Title II (i.e., Congress validly abrogated sovereign immunity) | Title II abrogates immunity for ADA harms; AOPC failed to provide services (docket monitoring/intervention) and thus denied benefits because of disability | AOPC is an arm of the Commonwealth and Title II does not abrogate immunity here because Geness did not identify a service AOPC provided that he was excluded from by reason of his disability | Reversed District Court; AOPC immune because Geness failed to state a plausible Title II claim against it |
| Whether AOPC’s administrative duties (Pa. R.J.A. No. 505) constitute a “service, program, or activity” under Title II | AOPC’s duties include monitoring dockets and reporting to the PA Supreme Court; it knew of Geness’s prolonged detention and failed to act | Those duties are systemwide administrative tasks and do not authorize intervening in or controlling specific litigation or judicial decision-making | Court: Pa. R.J.A. duties do not convert AOPC into a provider of the contested judicial-services function; insufficient to state Title II claim |
| Whether deliberate indifference (required for damages) is plausibly alleged | AOPC repeatedly inquired about his case and had access to prison/docket information; failure to act shows deliberate indifference | Allegations are conclusory/speculative and do not show action (or inaction) taken "by reason of" disability | Court did not reach deliberate-indifference analysis because plaintiff failed first to identify an excluded service under Title II |
| Effect of prior Third Circuit opinion finding Title II claim viable against the Commonwealth | Prior panel held a Title II claim against the Commonwealth was plausible; that supports claims against AOPC too | AOPC was not a party in the prior appeal and the opinion does not mandate AOPC liability | Court: prior decision binding only as to Commonwealth; it does not compel a Title II claim against AOPC given the different legal role alleged |
Key Cases Cited
- Tennessee v. Lane, 541 U.S. 509 (access-to-courts context for Title II and Eleventh Amendment analysis)
- United States v. Georgia, 546 U.S. 151 (three-part test for whether Congress validly abrogated state immunity under Title II)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading standard — facts must plausibly state a claim)
- Boddie v. Connecticut, 401 U.S. 371 (principle that states must, within practicable limits, afford meaningful opportunity to be heard)
- Disability Rights N.J., Inc. v. Comm’r, N.J. Dep’t of Human Servs., 796 F.3d 293 (defining what qualifies as a "service, program, or activity" under Title II)
- Furgess v. Pa. Dep’t of Corr., 933 F.3d 285 (Title II covers anything a public entity does; example of services provided by a prison)
- Geness v. Cox, 902 F.3d 344 (Third Circuit’s prior panel opinion finding a plausible Title II/Fourteenth Amendment claim against the Commonwealth)
- Haberle v. Troxell, 885 F.3d 171 (elements of a Title II claim and deliberate-indifference standard)
- Bowers v. NCAA, 475 F.3d 524 (discussing Title II's abrogation of sovereign immunity in certain contexts)
- Cooper v. Oklahoma, 517 U.S. 348 (incompetent defendant cannot be tried)
- Jackson v. Indiana, 406 U.S. 715 (standard for reasonable period to determine competency)