998 F.3d 474
1st Cir.2021Background:
- Plaintiff Emory Snell, a life-sentenced Massachusetts inmate, used a first-floor Lexis Nexis terminal and typewriter at MCI‑Concord for legal work for ~2+ years without any documented "no-stairs" medical restriction or formal accommodation.
- MCI‑Concord maintained a two-tier law library; the first‑floor Terminal was reserved as an accommodation for inmates with documented no‑stairs restrictions; the librarian allowed Snell informal access until October 2015.
- In October 2015 DOC officials revoked Snell's first‑floor Terminal access after concluding he lacked a qualifying medical restriction; Snell filed grievances and later sued DOC officials and his prison physician, Dr. Patricia Ruze.
- Dr. Ruze repeatedly opined Snell could climb stairs (and provided other treatments); in November 2018 a different physician, Dr. Churchville, issued a no‑stairs restriction and Snell was transferred to an accessible facility (MCI‑Shirley).
- The district court granted summary judgment to defendants on all claims; the First Circuit affirmed, holding injunctive/declaratory claims moot and rejecting claims for retaliation (ADA Title V), Eighth Amendment deliberate indifference, and denial of reasonable accommodation under Title II/Rehabilitation Act.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mootness of injunctive/declaratory relief | Transfer to accessible facility doesn’t moot claims because harm could recur and restrictions might not be renewed | Transfer to MCI‑Shirley ended the alleged injury; claims for injunctive/declaratory relief are moot | Held moot: transfer removed live controversy; no reasonable expectation of repetition |
| Retaliation (ADA §12203) | DOC and Dr. Ruze retaliated by removing Terminal access after Snell complained and litigated | Actions were nondiscriminatory: enforcement of rules and reliance on medical judgment | Held for defendants: no triable evidence Dr. Ruze took adverse action; DOC’s proffered reasons not shown to be pretextual |
| Eighth Amendment (deliberate indifference) | Forcing Snell to climb stairs aggravated medical conditions; withholding Terminal was cruel and unusual | Medical care and decisions (including denying a no‑stairs restriction) were within accepted professional judgment | Held for defendants: no inadequate care or deliberate indifference shown |
| ADA Title II / Rehabilitation Act (reasonable accommodation) | DOC denied reasonable accommodation (Terminal) because of disability | DOC reasonably required a medical no‑stairs restriction and deferred to medical staff and institutional security concerns | Held for defendants: denial was justified by lack of medical restriction and legitimate security/process reasons |
Key Cases Cited:
- Campbell‑Ewald Co. v. Gomez, 577 U.S. 153 (2016) (mootness principles for live controversies)
- Murphy v. Hunt, 455 U.S. 478 (1982) (appeal becomes moot when issues are no longer live)
- Ford v. Bender, 768 F.3d 15 (1st Cir. 2014) (inmate transfer may moot prison‑conditions claims)
- Barr v. Galvin, 626 F.3d 99 (1st Cir. 2010) (capable‑of‑repetition‑yet‑evading‑review exception)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden‑shifting framework for discrimination claims)
- D.B. ex rel. Elizabeth B. v. Esposito, 675 F.3d 26 (1st Cir. 2012) (elements and burdens for retaliation claims)
- Estelle v. Gamble, 429 U.S. 97 (1976) (Eighth Amendment deliberate indifference medical standard)
- Kosilek v. Spencer, 774 F.3d 63 (1st Cir. 2014) (application of Eighth Amendment medical‑care standards)
- Nunes v. Mass. Dept. of Corr., 766 F.3d 136 (1st Cir. 2014) (ADA/rehabilitation‑act analysis in prison context)