William Castle v. Eurofresh, Inc.
731 F.3d 901
9th Cir.2013Background
- Castle, an Arizona inmate required by state law to perform prison labor, worked off-site picking tomatoes for private employer Eurofresh through a contract between Eurofresh and Arizona Correctional Industries (ACI).
- Castle experienced severe ankle pain from the work, requested breaks or reassignment (e.g., pack-house or machine work), and contends Eurofresh refused reasonable accommodations; ADC later reassigned him to a lower-paying prison motor-pool job.
- Castle sued under Title I and II of the ADA and Section 504 of the Rehabilitation Act (RA) against Eurofresh and State Defendants (Arizona, ADC, and officials), seeking money damages for failure to accommodate.
- The district court dismissed Title I and RA claims against Eurofresh and later granted summary judgment to State Defendants, reasoning the State had accommodated Castle by reassigning him and lacked authority over Eurofresh’s job assignments.
- On appeal, the Ninth Circuit affirmed dismissal of Eurofresh (prisoner not an "employee" under Title I; Eurofresh not a recipient of federal funds under the RA) but reversed as to State Defendants, holding states can be liable under Title II/RA for discrimination by contractors and remanding to assess reasonableness of accommodations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Castle was an "employee" of Eurofresh under Title I ADA | Castle: his work for Eurofresh created an employment relationship entitling him to Title I protections | Eurofresh: Castle was compelled to work by prison program; his labor belongs to the State, not Eurofresh | Court: Not an employee — Hale/Coupar rule applies where inmate is obligated to work under prison program; Title I claim against Eurofresh fails |
| Whether Eurofresh is subject to the RA as a recipient of federal financial assistance | Castle: Eurofresh indirectly received federal assistance via ACI contract (e.g., ACI pays certain taxes), so RA applies | Eurofresh: No evidence Eurofresh affirmatively received federal funds or accepted conditions tied to federal assistance | Court: Dismissed RA claim against Eurofresh — plaintiff must plausibly allege Eurofresh received federal financial assistance; mere benefit or conduit theory insufficient |
| Whether State Defendants can be liable under Title II/RA for contractor’s discriminatory acts and whether reassignment was reasonable | Castle: State remains responsible for programs it provides and must ensure contractors accommodate disabilities; reassignment to motor pool may be inadequate | State: Lacked authority to change Eurofresh’s assignments; reassignment to WIPP motor-pool job was a reasonable accommodation | Court: State Defendants can be liable for contractor conduct under Title II/RA; remanded because district court made insufficient factual findings on whether the accommodation/modification was reasonable or fundamentally altered the program |
Key Cases Cited
- Hale v. Arizona, 993 F.2d 1387 (9th Cir. 1993) (prisoners obligated to work under prison programs are not employees for federal labor statutes)
- Coupar v. Dep’t of Labor, 105 F.3d 1263 (9th Cir. 1997) (applies Hale rule to prisoners obligated to work under prison programs for statutory protections limited to "employees")
- United States Dep’t of Transp. v. Paralyzed Veterans of Am., 477 U.S. 597 (U.S. 1986) (Rehabilitation Act liability limited to entities that actually receive federal financial assistance)
- Armstrong v. Schwarzenegger, 622 F.3d 1058 (9th Cir. 2010) (public entities remain liable under Title II for programs operated via contracts with third parties)
- Penn. Dep’t of Corr. v. Yeskey, 524 U.S. 206 (U.S. 1998) (Title II of the ADA applies to state prisons)