Wright v. New York State Dep’t of Corr., No. 15-3168 (2d Cir. 2016)
Annotate this CaseDefendant, a mobility‐impaired inmate who suffers from cerebral palsy and scoliosis, filed suit against DOCCS under Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and Section 504 of the Rehabilitation Act (RA), 29 U.S.C. 794, seeking declaratory and injunctive relief allowing him to use his motorized wheelchair within DOCCS facilities. The court held that the district court erred by granting summary judgment in favor of DOCCS because there is a genuine dispute of material fact as to whether the mobility assistance program provides plaintiff meaningful access to DOCCS services and as to whether allowing him the use of his motorized wheelchair would unduly burden DOCCS. The court also held that DOCCS’s blanket ban on motorized wheelchairs - without an individualized inquiry into the risks of allowing a mobility‐impaired inmate to use his or her motorized wheelchair - violates the ADA and the RA. Accordingly, the court vacated the district court's grant of summary judgment and remanded for further proceedings.
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