Craig v. Hughes
1:23-cv-02993
| N.D. Ill. | Jul 2, 2025Background
- Florencio Craig, a paraplegic former inmate at two Illinois correctional facilities (NRC and Pinckneyville), brought a class action under the ADA, Rehabilitation Act, and Illinois law, alleging denial of wheelchair-accessible showers.
- Plaintiff alleges that neither facility provided showers with ADA-compliant accessibility, citing the lack of mounted seats, grab bars, shower curbs, and inappropriate dimensions, making shower access unequal compared to non-disabled inmates.
- Plaintiff was provided with only a portable chair in the shower at both facilities, which he asserts was unsafe and inadequate, causing him to fall multiple times.
- The case initially focused class certification issues narrowly on mounted shower seats, but discovery uncovered additional accessibility violations including structural barriers like curbs and lack of grab bars or compliant dimensions.
- Both sides filed cross-motions for summary judgment on whether the lack of mounted seats (and related issues) at NRC and Pinckneyville violated ADA standards, but factual developments led the court to reconsider the certified issues.
- The court exercised its discretion to modify class certification issues to address broader structural accessibility claims and allowed parties to rebrief summary judgment on these expanded issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether complaint alleges ADA violations beyond lack of seats | Complaint covers all structural barriers | Only claims about mounted shower seats alleged | Complaint sufficient to put Defendant on notice of broader accessibility claims |
| Whether showers violate ADA due to lack of mounted seats | NRC showers must have mounted seats per ADA | Showers' dimensions don’t trigger seat requirement | NRA showers do not violate ADA standards only due to lack of seats (dimensions do not trigger) |
| Whether certified issues can be modified post-discovery | Modifying necessary based on new facts discovered | Should not broaden issues after certification | Court has discretion to modify certified class issues in light of new evidence |
| Standard for summary judgment and class proceedings | Parties entitled to summary judgment on merits | Narrow summary judgment per initial certification | Parties must re-brief summary judgment on amended, broadened issues after modification |
Key Cases Cited
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (Summary judgment standard applies: genuine disputes preclude judgment as a matter of law)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (Complaint must give fair notice of claims under federal pleading standards)
- Love v. Westville Corr. Ctr., 103 F.3d 558 (Elements for ADA claim in prison context)
- Lacy v. Cook Cnty., Illinois, 897 F.3d 847 (Structural barriers as discrimination under Title II of the ADA)
- Gen. Tel. Co. of Sw. v. Falcon, 457 U.S. 147 (District courts retain authority to modify class certifications as litigation proceeds)
- Fonder v. Sheriff of Kankakee Cnty., 823 F.3d 1144 (Class certifications are tentative and may be modified based on discovery and facts as they develop)
- Messner v. Northshore Univ. HealthSystem, 669 F.3d 802 (Courts may and should tailor class definitions to suit facts uncovered during litigation)