Hamilton v. Westchester Cnty.
3 F.4th 86
| 2d Cir. | 2021Background
- On Aug. 21, 2018, inmate Davonte Hamilton stepped on crumbled concrete in the Westchester County Jail yard, dislocating his knee and tearing his meniscus.
- Jail-contracted medical staff allegedly ignored a recommended immediate MRI, replaced a stabilizer with an inadequate bandage, and Hamilton experienced ongoing severe pain and mobility limits requiring crutches.
- Jail facilities (cracked floors, multi-step showers, lack of rails/benches, poor ventilation) allegedly made daily activities and showers extraordinarily painful and limited Hamilton’s access to recreational and basic services.
- Hamilton sued under 42 U.S.C. § 1983 and Title II of the ADA against Westchester County, certain county officials, CCS (medical contractor), and a doctor; the district court dismissed all claims, holding Hamilton’s injuries were temporary and thus not ADA disabilities.
- The Second Circuit held the district court erred to the extent it dismissed the ADA Title II claim against the County solely because the injuries were temporary, vacated that portion of the dismissal and remanded for further proceedings as to the ADA claim only; all other dismissals were affirmed.
- The Second Circuit also rejected the County’s exhaustion argument, concluding Hamilton plausibly alleged that administrative remedies were not meaningfully available.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a short-term/transitory injury can qualify as a "disability" under the ADA post-ADAAA | Hamilton: ADAAA expanded coverage; impairments lasting <6 months can qualify depending on severity and functional limitation | County: Temporary injuries do not meet the ADA "substantially limits" requirement; a 19-day injury here is too short | Court: Post-ADAAA, temporary impairments (including <6 months) can qualify; district court erred to categorically exclude short-term injuries; remand required |
| Whether dismissal under Rule 12(b)(6) was proper based solely on alleged temporariness | Hamilton: Complaint alleges severe, ongoing pain, inadequate treatment, and plausible inference injuries would last longer | County: Complaint fails to plead a qualifying disability or sufficient duration | Court: Complaint cannot be dismissed solely because plaintiff did not plead permanence; plausible allegations support inference of longer-lasting injury; other ADA elements left to district court to assess on remand |
| Whether Hamilton exhausted administrative remedies before suing | Hamilton: Grievances were ignored or rejected; exhaustion was not meaningfully available | County: Hamilton failed to exhaust administrative remedies | Court: Agreed with district court that Hamilton plausibly alleged exhaustion was not meaningfully available; County’s exhaustion defense rejected at this stage |
| Disposition of other claims (Section 1983, claims against medical defendants and county officials) | Hamilton: pursued deliberate indifference and failure-to-accommodate claims | Defendants: moved to dismiss all claims | Court: Affirmed dismissal of all claims except the County ADA Title II claim, which was vacated and remanded |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard for motions to dismiss)
- Ricci v. Teamsters Union Local 456, 781 F.3d 25 (2d Cir. 2015) (accept factual allegations as true on Rule 12(b)(6))
- Wright v. N.Y.S. Dep't of Corr., 831 F.3d 64 (2d Cir. 2016) (reasonable-accommodation "meaningful access" standard in prison context)
- Woolf v. Strada, 949 F.3d 89 (2d Cir. 2020) (ADA definition of "disability" post-ADAAA)
- Parada v. Banco Industrial De Venezuela, C.A., 753 F.3d 62 (2d Cir. 2014) (ADAAA interpreted to broaden coverage)
- Mancini v. City of Providence, 909 F.3d 32 (1st Cir. 2018) (short-term impairments <6 months can qualify as disabilities)
- Summers v. Altarum Inst. Corp., 740 F.3d 325 (4th Cir. 2014) (ADAAA rejects strict durational requirement for some actual-disability claims)
- Gogos v. AMS Mech. Sys., Inc., 737 F.3d 1170 (7th Cir. 2013) (post-ADAAA, impairments lasting six months or less may be covered)
- United States v. Georgia, 546 U.S. 151 (2006) (state prisons are "public entities" under Title II of the ADA)
- Toyota Motor Mfg., Ky., Inc. v. Williams, 534 U.S. 184 (2002) (pre-ADAAA narrow construction of "substantially limits")