Hutchinson v. California Department of Corrections and Rehabilitation
2:14-cv-02398
E.D. Cal.May 17, 2017Background
- Plaintiff Knolts Hutchinson, a paraplegic CDCR inmate, requires a wheelchair and assistance for bowel/bladder management; he previously sued CDCR in 2013 (case later dismissed).
- Transferred from California Medical Facility (CMF) to California Health Care Facility (CHCF) in Oct 2013; at issue are requests for a moveable/adjustable trapeze bar and a rolling commode chair.
- CHCF provided a trapeze bar (later an adjustable bed-mounted trapeze) and a stationary commode and shower chair; prison medical staff denied a rolling commode and wall-mounted trapeze as unsafe/medically unnecessary.
- Hutchinson sued CDCR and individual officials asserting: Title II ADA and Section 504 Rehabilitation Act violations, Title V ADA retaliation, California Disabled Persons Act and Unruh Act claims, and an Eighth Amendment deliberate-indifference claim under § 1983.
- Defendants moved for summary judgment; the court evaluated retaliation, reasonable accommodation/intentional discrimination, state-law claims against CDCR, and Eighth Amendment deliberate indifference.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Title V retaliation — transfer and denial of devices | Prior ADA lawsuit prompted transfer and denials; temporal proximity shows causation | Defendants lacked knowledge of prior suit; no adverse actions attributable to some defendants; timing alone insufficient | Summary judgment for defendants — plaintiff failed to show causation or adverse action for retaliation |
| Title II / §504 — failure to provide requested accommodations | Requested rolling commode and moveable trapeze were necessary to avoid discrimination and to perform bowel program | Requested devices were unsafe/medically unnecessary; CDCR provided reasonable, safe alternatives | Summary judgment for defendants — accommodations provided were reasonable; plaintiff failed to show intentional discrimination |
| State-law claims (CDPA, Unruh) against CDCR | California incorporated ADA standards into state statutes, so California waived sovereign immunity | CDCR (state agency) retains Eleventh Amendment immunity absent unequivocal waiver | Summary judgment for CDCR — Eleventh Amendment bars state-law claims against CDCR in federal court |
| §1983 Eighth Amendment deliberate indifference | Denial of plaintiff’s preferred devices amounted to deliberate indifference to serious medical needs | Decisions relied on medical staff recommendations and provided safe alternatives; no conscious disregard of substantial risk | Summary judgment for defendants — no deliberate indifference; medical need addressed with permissible measures |
Key Cases Cited
- Anderson v. Liberty Lobby, 477 U.S. 242 (summary judgment standard and credibility/jury role)
- Celotex Corp. v. Catrett, 477 U.S. 317 (movant’s initial summary judgment burden)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (nonmoving party must show genuine dispute)
- Duvall v. County of Kitsap, 260 F.3d 1124 (9th Cir. 2001) (Title II monetary damages require intentional discrimination/deliberate indifference)
- Weinreich v. Los Angeles County Metro. Transp. Auth., 114 F.3d 976 (reasonable accommodation analysis under Title II)
- Zivkovic v. Southern California Edison Co., 302 F.3d 1080 (employer need not provide employee’s requested accommodation)
- Turner v. Safley, 482 U.S. 78 (prison regulations valid if reasonably related to penological interests)
- Farmer v. Brennan, 511 U.S. 825 (deliberate indifference standard)
- Estelle v. Gamble, 429 U.S. 97 (Eighth Amendment deliberate indifference to serious medical needs)
- Seminole Tribe of Florida v. Florida, 517 U.S. 44 (state sovereign immunity principles)
- Pennhurst State School & Hospital v. Halderman, 465 U.S. 89 (Eleventh Amendment bars pendent state-law claims)
- Hans v. Louisiana, 134 U.S. 1 (foundational Eleventh Amendment precedent)