Geness v. Administrative Office of Pennsylvania Courts, No. 19-2253 (3d Cir. 2020)
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In 2006, a McVey assisted living resident fell and suffered injuries that resulted in his death. An investigation led to a homicide charge against Geness, a permanently mentally disabled McVey resident. A judge deemed Geness incompetent to stand trial and ordered him transferred to a psychiatric hospital for assessment. Approximately 10 months after his arrest, Geness was transferred to a psychiatric facility where he was deemed incompetent with a “poor” prognosis for improvement. He remained imprisoned for years, while his case remained on the court’s monthly “call of the list.” About five years after Geness’s arrest, a second competency evaluation was conducted, at the prison. It was again determined that Geness was incompetent to stand trial and unlikely to improve. A judge released him for involuntary commitment to a Long Term Structured Residence. Geness’s case remained the monthly “call of the list.” In 2015, a judge entered a nolle prosequi order. After nine years in custody without a trial, Geness was released.
Geness sued the county and city, former detective Cox, and McVey under the Americans with Disabilities Act, 42 U.S.C. 12131, and the Fourteenth Amendment, 42 U.S.C. 1983. All defendants were dismissed except Cox. Following a remand, Geness added ADA “Title II” and Fourteenth Amendment claims against the Commonwealth and the Administrative Office of Pennsylvania Courts (AOPC). The Third Circuit remanded for dismissal of AOPC. While Congress abrogated sovereign immunity for Title II claims, Geness has not stated a Title II claim against AOPC, which had no power over the disposition of his case. There is no allegation regarding how AOPC’s alleged failure to contact the Supreme Court connects to Geness’s disability.
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