Pennsylvania Department of Corrections v. Yeskey
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Ronald Yeskey was convicted of a crime and sentenced to serve 18 to 36 months in a Pennsylvania correctional facility; the sentencing judge recommended that Yeskey be placed in a Motivational Boot Camp for first-time offenders. Successful completion of the boot camp program would have made Yeskey eligible for release on parole in six months. Yeskey was refused admission to the boot camp because he had a history of hypertension. Yeskey sued the Pennsylvania Department of Corrections and several corrections officials under Title II of ADA, alleging that his exclusion from the boot camp constituted discrimination on the basis of disability. The district court dismissed Yeskey's case for failure to state a claim; it ruled that ADA does not apply to inmates in state prisons. The Third Circuit Court of Appeals disagreed and reversed the district court's decision.
In a unanimous opinion delivered by Justice Scalia, the Supreme Court ruled that ADA does cover state prisons and prisoners. The Court considered in turn and rejected several arguments put forth by the correctional officials. First, the officials contended that federal laws should not be interpreted to cover traditional and essential state functions, such as prisons, unless the language of the statute makes the coverage of such functions "unmistakably clear." Id. at 208-09, quoting Gregory v. Ashcroft, 501 U.S. 452, 460-61 (1991). The Supreme Court assumed without deciding that the "unmistakably clear" standard applies to ADA's coverage of state prisons, but ruled, however, that this requirement is "amply met" by Title II of ADA. 524 U.S. at 209. The Court declared that "the statute's language unmistakably includes State prisons and prisoners within its coverage." Id.
The prison officials contended that ADA's prohibition of discrimination in regard to the "benefits of the services, programs, or activities of a public entity," 42 U.S.C. § 12132, could not apply to state prisons because they do not provide "benefits" of "services, programs, or activities." The Supreme Court rejected this argument, finding that modern prisons provide inmates with many recreational activities, medical services, and educational and vocational services that prisoners may benefit from. The Court noted that the boot camp that Yeskey was excluded from was described as a "program" in the statute that established it.
The state officials also argued that the term "qualified individual with a disability" in ADA is defined as including those who meet "essential eligibility requirements for the receipt of services or the participation in programs or activities," Id., § 12131(2), and that the words "eligibility" and "participation" imply voluntariness that does not fit the situation of prisoners. The Supreme Court ruled that these words do not connote voluntariness, as one can be eligible and participate even if participation is required for those prisoners who are eligible. Even if the words did connote voluntariness, said the Court, the use of various services at prisons, including prison law libraries, is clearly on a voluntary basis. Participation in the boot camp program involved in the case was voluntary under Pennsylvania law.
The prison officials argued that the statement of findings and purpose in ADA does not mention prisons or prisoners and that Congress did not envision the law's application in the context of prisons. The Court questioned the contention that ADA does not mention prisons, since the Act refers to "institutionalization," Id., § 12101(a)(3), which the Court noted can be thought of as including "penal institutions." But even if ADA did not mention prisons and Congress never considered them in its ADA deliberations, the Court said that it would not matter because ADA's text is unambiguous. The Court recited a principle that it had applied in other contexts in which it had declared that "the fact that a statute can be 'applied in situations not expressly anticipated by Congress does not demonstrate ambiguity. It demonstrates breadth.'" 524 U.S. at 212, quoting Sedima, S.P.R.L. v. Imrex Co., 473 U.S. 479, 499 (1985).
Because it found ADA to be unambiguous as to coverage of prisons, the Court also rejected the state officials' contentions regarding the implications of Title II of ADA's title, "Public Services," and the application of a doctrine called "constitutional doubt." The Court ruled that these arguments would be applicable only if the statutory language was ambiguous. Ultimately, the Supreme Court affirmed the judgment of the Third Circuit "[b]ecause the plain text of Title II of ADA unambiguously extends to state prison inmates ...." 524 U.S. at 213.