Epley v. Gonzalez, 19-10781

Plaintiff Charles Epley, a former long-term TDCJ inmate, suffers from PTSD and traumatic brain injury and had a longstanding single-cell medical restriction and work limitations.
After transfer to the Montford Unit (a psychiatric prison), staff ordered him into a multi-occupancy cell; he alleges severe PTSD/TBI symptoms, forced removal, exposure to a gaseous agent, and a physical assault by guards, after which he was placed back in the multi-occupancy cell.
The next day he was transported 170 miles in a prison bus in restraints, worsening his injuries.
Epley filed a pro se civil-rights complaint asserting many claims (excessive force, denial of medical care, ADA and § 504 disability-discrimination claims, etc.).
A magistrate judge recommended dismissal under 28 U.S.C. § 1915(e)(2) for failure to state a claim or as frivolous; the district court adopted that recommendation and dismissed the case.
On appeal the Fifth Circuit considered only the ADA and § 504 discrimination claims and reversed dismissal as to those claims, concluding Epley adequately pleaded a qualifying disability, a record of impairment, and denial of reasonable accommodations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Epley's PTSD/TBI qualify as a disability under the ADA	Epley's PTSD/TBI substantially limit major life activities (thinking, sleeping) and he has a documented single-cell restriction	Epley did not plead facts showing a qualifying disability	Held: Yes — allegations sufficiently plead disability and a record of impairment (single-cell restriction)
Whether defendants discriminated "by reason of" disability (failure to accommodate)	Montford officials knew of his restriction and nevertheless forced him into multi-occupancy housing and used non-medical transport	No intentional discrimination; no facts showing treatment because of disability	Held: Yes — plaintiff plausibly alleged officials knew of his limitations/accommodation and denied reasonable accommodations
Whether the ADA/§504 claims merely duplicate Epley's denial-of-medical-care claims	ADA claims seek accommodations (housing, transport) distinct from medical treatment	ADA claim is just a restatement of medical-care allegations	Held: No — accommodation claims are distinct from claims alleging denial of medical treatment
Whether dismissal under §1915(e)(2) was proper as to the disability claims	Epley argued dismissal was premature as he stated plausible ADA/§504 claims	Magistrate and district court found failure to state a claim/frivolous	Held: Reversed as to ADA and §504 claims; remanded for further proceedings

Melton v. Dallas Area Rapid Transit, 391 F.3d 669 (5th Cir. 2004) (elements of a prima facie Title II ADA claim)
Valentine v. Collier, 993 F.3d 270 (5th Cir. 2021) (failure-to-accommodate framework under Title II)
Windham v. Harris Cty., 875 F.3d 229 (5th Cir. 2017) (accommodation requirement and ADA claims against public entities)
Cadena v. El Paso Cty., 946 F.3d 717 (5th Cir. 2020) (knowledge and limitations required to establish entitlement to accommodation)
Bennett-Nelson v. La. Bd. of Regents, 431 F.3d 448 (5th Cir. 2005) (parallel analysis for Title II ADA and § 504)
Black v. Warren, 134 F.3d 732 (5th Cir. 1998) (standard of review for §1915 dismissals)
Nottingham v. Richardson, [citation="499 F. App'x 368"] (5th Cir. 2012) (unpublished) (noting limits on ADA claims that merely restate medical-care claims)
Walls v. Texas Dep’t of Criminal Justice, [citation="270 F. App'x 358"] (5th Cir. 2008) (unpublished) (similar point regarding overlap with medical-care claims)