Melvin Folkerts v. City of Waverly, 707 F.3d 975

Folkerts are guardians and conservators for their adult son Travis Folkerts, who has severe intellectual disability.
In May 2008 Travis was investigated for sexual conduct with a minor; a police officer and Schneider conducted the interrogation.
Travis was read Miranda rights; a caseworker was contacted and a report was forwarded for follow-up.
Schneider conducted further interrogation at the station, altered questioning, and claimed to accommodate Travis’s disability; Idella was contacted by phone.
Folkerts sued under 42 U.S.C. § 1983, the ADA, and the Rehabilitation Act, alleging due process violations and failure to reasonably accommodate.
District court granted summary judgment for defendants; on appeal the court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Schneider’s conduct violated substantive due process.	Folkerts contend conduct shocks conscience by mishandling interrogation.	Schneider’s actions were reasonable, adapted to Travis’s disability, not conscience-shocking.	No due process violation; qualified immunity applies.
Whether the investigation and charging decisions shock due process or reflect conscience-shocking conduct.	Investigation allegedly negligent or retaliatory against relatives.	No intentional or reckless failure to investigate; no retaliation shown.	No conscience-shocking misconduct; no § 1983 violation.
Whether the city’s alleged ‘culture of indifference’ constitutes deliberate indifference requiring municipal liability.	Evidence of systemic indifference to disabled individuals supports liability.	No pattern of constitutional violations; no single violation shown.	District court properly granted summary judgment; no municipal liability.
Whether the § 504 Rehabilitation Act and Title II ADA claims against Schneider and the City survive summary judgment.	Interrogation and accessibility failures denied meaningful access and accommodations.	Accommodations provided (e.g., Miranda explanation, room choice, transport, and Idella call) were reasonable.	No violation; accommodations were reasonable; no discrimination.

County of Sacramento v. Lewis, 523 U.S. 833 (1998) (threshold for conscience-shocking conduct; culpability level in due process)
Harlow v. Fitzgerald, 457 U.S. 800 (1982) (qualified immunity standard)
Bd. of Cnty. Comm’rs of Bryan Cnty., Okla. v. Brown, 520 U.S. 397 (1997) (deliberate indifference and municipal liability; pattern or single violation may suffice)
City of Los Angeles v. Heller, 475 U.S. 796 (1986) (no constitutional violation without underlying violation by officers)
Akins v. Epperly, 588 F.3d 1178 (2009) (deliberate indifference standard; conscience-shocking inquiry)
Frye v. Kansas City Mo. Police Dep’t, 375 F.3d 785 (2004) (attention to reasonableness of Miranda-related actions)