Wright v. New York State Department of Corrections
2016 U.S. App. LEXIS 13809
| 2d Cir. | 2016Background
- Nathaniel Wright, a prisoner with cerebral palsy and scoliosis, used a doctor‑prescribed motorized wheelchair for years before incarceration; DOCCS confiscated it and provided a manual wheelchair, cane, cushion, knee pads, and inmate "mobility aides."
- DOCCS maintains a blanket policy banning inmate use of motorized wheelchairs; mobility‑impaired inmates who cannot self‑propel must request inmate aides “well in advance.”
- Wright alleges the mobility assistance program is unreliable and prevents meaningful access to programs, services, medical care, jobs, recreation, and the law library; he sometimes soiled himself trying to reach the bathroom.
- DOCCS defends its policy on safety/security and administrative grounds (weight, batteries, wiring, contraband, narrow hallways, inspection/maintenance burdens); it did not perform an individualized assessment of Wright or his particular chair.
- The district court granted summary judgment to DOCCS, holding the mobility assistance program was a reasonable accommodation and Wright failed to pursue administrative remedies; the Second Circuit vacated and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether DOCCS’ mobility assistance program is a reasonable accommodation under ADA/RA | Wright: program is ineffective and unreliable, deters participation, so it does not provide meaningful access | DOCCS: manual chair, cushion, cane, and mobility aides adequately meet needs | Court: genuine dispute of material fact exists; program not plainly reasonable as a matter of law |
| Whether DOCCS’ blanket ban on motorized wheelchairs violates ADA/RA | Wright: blanket ban denies individualized consideration and may be unlawful | DOCCS: blanket ban justified by prison security/administration concerns | Court: blanket ban violates ADA/RA because it forecloses individualized inquiry; individualized assessment required |
| Whether allowing Wright to use his motorized wheelchair would unduly burden DOCCS | Wright: his personal chair poses low risk; many jurisdictions allow case‑by‑case use; costs minimal | DOCCS: safety (weight, hallways, batteries, contraband) and administrative burdens (inspections, maintenance) justify denial | Court: material factual dispute remains whether permitting Wright would cause undue hardship; remand for factfinder |
| Whether Wright’s failure to formally grieve/engage in interactive process bars relief | DOCCS: Wright did not follow interactive process or adequately grieve; relief inappropriate | Wright: made informal complaints and counsel sent letters; DOCCS did not engage or assess his individual needs | Court: DOCCS’ failure to engage defeats this defense; grievence/interactive‑process failure not a basis for summary judgment for DOCCS |
Key Cases Cited
- Henrietta D. v. Bloomberg, 331 F.3d 261 (2d Cir.) (ADA/RA standards and meaningful access framework)
- PGA Tour, Inc. v. Martin, 532 U.S. 661 (2001) (ADA requires individualized inquiry before denying a requested modification)
- Dean v. Univ. at Buffalo Sch. of Med. & Biomedical Scis., 804 F.3d 178 (2d Cir.) (hallmark of reasonable accommodation is effectiveness; burden‑shifting framework)
- Noll v. Int’l Bus. Machs. Corp., 787 F.3d 89 (2d Cir.) (reasonable accommodation need not be plaintiff’s preferred but must be effective)
- Yeskey v. Pa. Dep’t of Corrections, 524 U.S. 206 (1998) (ADA applies to state prisons and prisoners)
- Disabled in Action v. Bd. of Elections in City of N.Y., 752 F.3d 189 (2d Cir.) (deterrence from access is an ADA injury)
- Pierce v. Cty. of Orange, 526 F.3d 1190 (9th Cir.) (deference to prison administrators on security but accommodation costs evaluated under burden‑shifting)