Jaros v. Illinois Department of Corrections
2012 U.S. App. LEXIS 13548
7th Cir.2012Background
- Jaros, a former inmate, sues the Illinois Department of Corrections for violations of the Rehabilitation Act and ADA, and for Eighth Amendment claims arising from Vandalia Correctional Center's alleged noncompliance and lack of accommodations.
- Jaros has advanced hip disability with osteoarthritis and vascular necrosis; he uses a cane and requires grab bars for showering and toileting, and private doctors recommended a hip replacement.
- Vandalia is not ADA-compliant and lacks grab bars; Jaros requested accommodations and transfer, which staff did not grant, citing policy and transfer criteria.
- Jaros was denied work-release consideration due to a medical hold tied to cane use, despite some staff acknowledging Jaros’ health as potentially suitable for work release.
- District court dismissed the claims at screening, including Rehabilitation Act/ADA claims and Eighth Amendment claim; Jaros appeals challenging the dismissals.
- Appellate court vacates only the Rehabilitation Act/ADA discrimination and accommodation claims, remanding for further proceedings, while affirming the Eighth Amendment dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Jaros states a Rehabilitation Act/ADA failure-to-accommodate claim. | Jaros pleads plausible failure to accommodate due to lack of grab bars and transfer limitations. | IDOC cannot be liable or lacks actionable denial of accommodations under immunity or policy constraints. | Plausible failure-to-accommodate claim stated; remanded. |
| Whether Jaros states Rehabilitation Act/ADA discrimination by work-release denial based on cane. | Medical hold was placed solely because of cane, blocking work release as discrimination. | Decision was based on policy and placement considerations, not disability. | Plausible discrimination claim stated; remanded. |
| Whether Jaros's Eighth Amendment claim survives. | Without grab bars, confinement caused pain and hindered basic bodily functions. | Jaros still had access to meals and basic facilities; no denial of life's necessities. | Eighth Amendment claim dismissed. |
Key Cases Cited
- Rhodes v. Chapman, 452 U.S. 337 (U.S. 1981) (minimal civilized needs include sufficient food and facilities)
- Wilson v. Seiter, 501 U.S. 294 (U.S. 1991) (standards for prison conditions under Eighth Amendment )
- Vinning-El v. Long, 482 F.3d 923 (7th Cir. 2007) (substantive Eighth Amendment analysis for prison conditions)
- Cassidy v. Ind. Dep't of Corr., 199 F.3d 374 (7th Cir. 2000) (meals and showers are access to prison programs)
- Crawford v. Ind. Dep't of Corr., 115 F.3d 481 (7th Cir. 1997) (Eighth Amendment considerations in prison conditions)
- Alexander v. Choate, 469 U.S. 287 (U.S. 1985) (reasonable accommodations under disability statutes)
- Wis. Cmty. Serv. v. City of Milwaukee, 465 F.3d 737 (7th Cir. 2006) (coverage and duty to accommodate under Rehabilitation Act)
- Grzan v. Charter Hosp. of Nw. Ind., 104 F.3d 116 (7th Cir. 1997) (Rehabilitation Act eligibility standards and remedies)
- Foley v. City of Lafayette, 359 F.3d 925 (7th Cir. 2004) (limitations on sovereign immunity considerations in disability claims)
- Duran v. Town of Cicero, Ill., 653 F.3d 632 (7th Cir. 2011) (remand and procedural pathways in disability claims)