Matthews v. Pennsylvania Department of Corrections
613 F. App'x 163
3rd Cir.2015Background
- Matthews, an inmate at SCI‑Somerset, developed left‑heel/ankle pain diagnosed as Achilles tendinitis in 2011; he limped and later received an air cast, then a fiberglass cast and crutches.
- He requested wheelchair access and reassignment to a lower bunk/lower‑tier cell; medical staff did not recommend reassignment and a requested wheelchair was denied.
- As a result, Matthews alleges he frequently missed meals, phone access, commissary, recreation, and religious services; he fell down stairs on July 31, 2011, and only then received a lower bunk on a bottom tier.
- Matthews sued under 42 U.S.C. § 1983 (Eighth Amendment), Title II of the ADA, and the Rehabilitation Act against the Pennsylvania DOC, two corrections officers, medical staff, and a private medical contractor.
- The District Court dismissed for failure to state a claim; Matthews appealed. The Third Circuit affirmed the § 1983 dismissal, affirmed dismissal of ADA/Rehab Act claims against individual officers, medical personnel, and the private contractor, but vacated and remanded the ADA/Rehab Act claims against the Pennsylvania DOC.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Matthews alleged a "disability" under the ADA/Rehab Act | Matthews: his impairment substantially limited walking for several months (missed meals, phone access, needed wheelchair) | Defendants: impairment was short/ minor — ordinary mobility degradation not a disability | Court: on a motion to dismiss, allegations suffice to plausibly plead a disability (individualized inquiry; temporary impairments can qualify) |
| Whether Matthews was denied benefits/participation because of disability | Matthews: placement in upper‑tier cell and lack of reasonable modification (lower bunk/tier) deprived him of meals, phone, services | Defendants: medical restrictions on activities were treatment decisions; prison policies justified for security; no causal denial | Court: pleaded denial of core benefits (meals, counts) that reasonable accommodation could have avoided; claim against DOC survives |
| Whether private defendants and individual officers are liable under Title II / Rehab Act | Matthews: sued DOC employees and contractor under statutes | Defendants: Title II applies only to public entities, not individuals or private contractors | Court: Title II/Rehab Act claims against officers, medical staff, and private contractor dismissed — they are not "public entities" under Title II |
| Whether defendants were deliberately indifferent under Eighth Amendment (§ 1983) | Matthews: failure to secure lower bunk/tier caused risk/harm (fall) | Defendants: medical staff treated him; officers reasonably relied on medical providers; at most negligence | Court: affirmed dismissal — medical staff attentive and officers justified in relying on them; allegations show negligence, not deliberate indifference |
Key Cases Cited
- Fowler v. UPMC Shadyside, 578 F.3d 203 (3d Cir. 2009) (standard of review for motions to dismiss)
- Santiago v. Warminster Twp., 629 F.3d 121 (3d Cir. 2010) (pleading standards and inferences at dismissal)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (facial plausibility standard)
- Albertson’s, Inc. v. Kirkingburg, 527 U.S. 555 (1999) (individualized inquiry into substantial limitation)
- Toyota Motor Mfg., Ky., Inc. v. Williams, 534 U.S. 184 (2002) (pre‑ADAAA interpretation of disability)
- Summers v. Altarum Inst., 740 F.3d 325 (4th Cir. 2014) (temporary but severe mobility impairments can be disabilities under ADAAA)
- Macfarlan v. Ivy Hill SNF, LLC, 675 F.3d 266 (3d Cir. 2012) (ADA and Rehabilitation Act standards construed consistently)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference requires actual knowledge of risk)
- Estelle v. Gamble, 429 U.S. 97 (1976) (examples of deliberate indifference in medical care)
- Spruill v. Gillis, 372 F.3d 218 (3d Cir. 2004) (non‑medical officials may rely on medical staff absent reason to doubt treatment)
- Garcia v. S.U.N.Y. Health Sci. Ctr. of Brooklyn, 280 F.3d 98 (2d Cir. 2001) (Title II does not permit suits against state officers individually)
- Edison v. Douberly, 604 F.3d 1307 (11th Cir. 2010) (private contractor providing services to government is not a Title II "public entity")