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UNITED STATES v. GEORGIA Stevens, J., concurring
ing their rights nor what they are being held for”); id., at 1005 (stating that police arrested a man with AIDS and “[i]n stead of putting the man in jail, the officers locked him inside his car to spend the night”); California Dept. of Justice, At torney General’s Commission on Disability: Final Report 103 (Dec. 1989) (finding that inmates with disabilities were un necessarily “confined to medical units where access to work, job training, recreation and rehabilitation programs is lim ited”). In fact, as the Solicitor General points out in his brief arguing that Title II’s damages remedy constitutes ap propriate prophylactic legislation in the prison context, the record of mistreatment of prison inmates that Congress re viewed in its deliberations preceding the enactment of Title II was comparable in all relevant respects to the record that we recently held sufficient to uphold the application of that title to the entire class of cases implicating the fundamental right of access to the courts. See Lane, 541 U. S., at 533– 534. And while it is true that cases involving inadequate medical care and inhumane conditions of confinement have perhaps been most numerous, courts have also reviewed myriad other types of claims by disabled prisoners, such as allegations of the abridgment of religious liberties, undue censorship, interference with access to the judicial process, and procedural due process violations. See, e. g., Vitek v. Jones, 445 U. S. 480 (1980) (procedural due process); May v. Sheahan, 226 F. 3d 876 (CA7 2000) (access to judicial process, lawyers, legal materials, and reading materials); Littlefield v. Deland, 641 F. 2d 729 (CA10 1981) (access to reading and writing materials); Nolley v. County of Erie, 776 F. Supp. 715 (WDNY 1991) (access to law library and religious services). Indeed, given the constellation of rights applicable in the prison context, it is clear that the Eleventh Circuit has erred in identifying only the Eighth Amendment right to be free from cruel and unusual punishment in performing the first step of the “congruence and proportionality” inquiry set
