Lee v. Corrections Corp. of America/Correctional Treatment Facility
61 F. Supp. 3d 139
D.D.C.2014Background
- Melvin Lee, a D.C. detainee who uses a prosthetic right leg, was housed at the privately run Correctional Treatment Facility (CTF) operated by Corrections Corporation of America (CCA).
- A federal magistrate ordered prompt medical evaluation/treatment for Lee while detained in April 2011; Lee was initially in CTF’s medical unit.
- In mid-May 2011 Lee was moved from the medical unit to Unit D, which was not handicap-accessible; staff told him he would be returned to the medical unit.
- Before a transfer back could occur, a CTF employee ordered Lee to descend a flight of stairs for an inmate count; Lee attempted to go down unassisted, fell, and suffered serious injuries.
- Lee sued CCA asserting negligence and claims under Title II of the ADA and §504 of the Rehabilitation Act; CCA moved to dismiss. Lee later dropped several other claims.
- The court dismissed Lee’s ADA and Rehabilitation Act claims but denied dismissal of his negligence claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether CCA is a "public entity" under Title II of the ADA | Lee: CCA’s operation of a detention facility subjects it to Title II liability for denying access and transferring him to an inaccessible unit | CCA: As a private contractor, it is not a "public entity" and thus not directly liable under Title II | Court: CCA is not a public entity under Title II; ADA claim dismissed |
| Whether CCA is subject to §504 of the Rehabilitation Act (receives Federal financial assistance) | Lee: CCA’s federal contracts bring it within §504 coverage | CCA: Contract payments are compensation for services, not federal financial assistance/subsidies | Court: Payments do not constitute federal financial assistance; Rehab Act claim dismissed |
| Whether Lee plausibly alleged negligence against CCA | Lee: CCA’s employees ordered him to descend stairs unassisted despite his disability, breaching a duty to protect detainees | CCA: (argued dismissal) fault tied to transfer decision, not an actionable duty alleged | Court: Lee stated a plausible negligence claim—duty to protect detainees and supervise employees exists; negligence claim survives |
| Scope of relief at Rule 12(b)(6) stage (pleading sufficiency) | Lee: Complaint alleges factual circumstances supporting claims | CCA: Allegations are insufficient as a matter of law for statutory claims | Court: Applied Twombly/Iqbal plausibility standard; statutory claims fail on legal grounds, negligence survives factual plausibility review |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (establishes pleading plausibility standard)
- Ashcroft v. Iqbal, 556 U.S. 662 (applies and clarifies Twombly pleading standard)
- Pa. Dep’t of Corr. v. Yeskey, 524 U.S. 206 (Title II covers prison settings)
- Edison v. Dauberly, 604 F.3d 1307 (11th Cir.) (private prison operator is not a Title II "public entity")
- Toy v. Dist. of Columbia, 549 A.2d 1 (D.C. Ct. App.) (common-law duty to protect and safely supervise prisoners)