Mark Wells v. Nathaniel Quarterman
460 F. App'x 303
5th Cir.2012Background
- Wells is a 52-year-old blind prisoner convicted in 2006 of aggravated sexual assault of a child and confined at the Estelle Unit since Oct 2006.
- He sues under 42 U.S.C. § 1983 and Title II of the ADA against various TDCJ and UTMB officials, seeking damages and injunctive relief.
- Wells contends that Estelle Unit’s library and Adaptive Resource Clinic failed to provide adequate accommodations for his disability, hindering federal and state habeas filings.
- From June 2007 Wells used prison readers in the law library, typically Chris Cole, reading and reading-related tasks via CCTV, with no accommodations beyond reader assistance initially.
- Grievances in 2007–2008 sought more assistive technology (screen-reading software, Braille/audio resources, Westlaw/Lexis), which staff denied or deemed unnecessary beyond existing services.
- The district court granted summary judgment; the court affirmed, finding no triable issues on the merits and dismissing damages claims and requests for prospective relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Wells had actionable access-to-courts injuries | Wells alleges denial of meaningful research access due to disability | Access via reader assistance and library resources satisfied constitutional requirement | No genuine issue; access adequate; no actual injury shown |
| Whether mail access violations occurred | Inadequate accommodations impaired mail communication | Existing resources and assistance sufficed; Wells declined some help | No violation; mail access adequately provided |
| Whether Title II against state actors in damages is barred by sovereign immunity | Title II abrogates sovereign immunity for disability discrimination; damages allowed | Abrogation not established for the conduct at issue; immunity applies | State immunity defeated for damages not shown; immunity preserved; damages claims dismissed |
| Whether the accommodations provided were sufficient under Title II | Computer with screen-reading software and Braille/audio resources required | Existing accommodations (qualified reader, available resources) were sufficient and effective | Accommodations adequate; no Title II violation shown |
| Whether amendments to Title II (ADAAA-era) affect Wells’ prospective relief claims | Amendments could change requirements for prospective relief | Amendments not retroactive for compensatory damages; waiver concerns for prospective relief | Amendments waived; no error in dismissing prospective relief |
Key Cases Cited
- Bounds v. Smith, 430 U.S. 817 (1977) (prisoners have right of access to courts, not a right to a law library)
- Lewis v. Casey, 518 U.S. 343 (1996) (access to courts is for ensuring nonfrivolous claims; not a freestanding right to libraries)
- McDonald v. Steward, 132 F.3d 225 (5th Cir. 1998) (actual injury required for access-to-the-courts claim)
- Johnson v. Rodriguez, 110 F.3d 299 (5th Cir. 1997) (supporting that meaningful access can be met through available means)
- Georgia v. United States, 546 U.S. 151 (2006) (three-part test for abrogation of sovereign immunity under Title II)
- Hale v. King, 642 F.3d 492 (5th Cir. 2011) (standard for evaluating Title II discrimination claims post-abrogation)
- Mason v. Corr. Med. Servs., Inc., 559 F.3d 880 (8th Cir. 2009) (ADA accommodations in prison context can be adequate and not always ideal)