428 F. App'x 224
3d Cir.2011Background
- Zied-Campbell, a disabled individual, sued DPW and YCAO employees in district court under ADA Title II, ADA Title IV, and Rehabilitation Act.
- Plaintiffs claimed defendants failed to provide reasonable accommodations and engaged in retaliatory conduct by denying benefits.
- District Court granted judgment on the pleadings in part and summary judgment on remaining claims, limiting capacity to sue and the availability of damages.
- The court held Title II damages against officials in their official capacities barred by sovereign immunity; retaliation claims under Rehab Act were not cognizable; and Title II damages were barred for other reasons.
- Appellate briefing included motions to amend, recusal arguments, and motions to file supplemental briefs; the United States intervened.
- Court of appeals affirmed the district court, rejecting arguments for amendment or recusal and denying relief on the remaining claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does sovereign immunity bar Title II damages against officials? | Zied-Campbell argues damages are cognizable after abrogation of immunity. | U.S. and appellees contend sovereign immunity or independent grounds foreclose damages. | Affirmed on independent grounds; damages barred or defeated on summary judgment. |
| Was there abuse of discretion in denying a second amended complaint? | Zied-Campbell sought leave to amend after counsel changes. | District Court properly denied due to Local Rules noncompliance. | No abuse; district court acted within discretion given noncompliance with Local Rules. |
| Did the district court err regarding recusal/bias claims? | Judge Kane biased due to rulings and alleged mischaracterizations. | Judicial rulings alone do not warrant recusal; no other bias shown. | No reversible bias; recusal not warranted. |
Key Cases Cited
- Lake v. Arnold, 232 F.3d 360 (3d Cir. 2000) (abuse of discretion standard for leave to amend)
- In re Kensington Int'l Ltd., 353 F.3d 211 (3d Cir. 2003) (adequacy of record for recusal; developed record exception)
- Singleton v. Wulff, 428 U.S. 106 (U.S. 1976) (bias not established by judicial rulings alone)
- Liteky v. United States, 510 U.S. 540 (U.S. 1994) (extrajudicial bias standard; rulings alone insufficient)
- Weil v. Neary, 278 U.S. 160 (U.S. 1929) (local rule authority and enforceability; rules have force)
- Spence v. ESAB Group, Inc., 623 F.3d 212 (3d Cir. 2010) (plenary review of district court orders; standard of review)
- Leamer v. Fauver, 288 F.3d 532 (3d Cir. 2002) (plenary review for judgments on the pleadings and summary judgment)
- Hughes v. Long, 242 F.3d 121 (3d Cir. 2001) (affirming district court on appeal; grounds to affirm)