Rinehart v. Weitzell, No. 18-3263 (8th Cir. 2020)
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The Eighth Circuit reversed the district court's sua sponte dismissal of plaintiff's in forma pauperis complaint as failing to state a claim under the Americans with Disabilities Act (ADA). Plaintiff is currently serving a prison sentence and has a diagnosis of diverticulitis, a chronic colon condition that causes diarrhea and constipation.
The court held that plaintiff has stated a Title II claim by sufficiently alleging that he is a qualified individual with a disability under the ADA and that he was denied the benefit of the prison's privilege system by reason of his disability. The court also held that plaintiff has stated a claim under Title VI and that defendants retaliated against him for his filing of ADA grievances by taking the adverse action of rescinding his medical classification without providing a medical reevaluation or rationale. Finally, because plaintiff's complaint sufficiently states a claim upon which relief may be granted, the court necessarily reversed the district court's assignment of a strike under the Prison Litigation Reform Act.
Court Description: [Melloy, Author, with Kelly and Kobes, Circuit Judges] Prisoner case - Americans with Disabilities Act. In action alleging prison officials violated the ADA by denying plaintiff access to the privileges for which he was otherwise eligible because of his diverticulitis and by retaliating against him for filing his ADA grievances by revoking his medical classification, the district court erred in dismissing the complaint for failure to state a claim upon which relief could be granted; plaintiff stated a Title II claim under the ADA as he sufficiently alleged he was a qualified individual with a disability and that he was denied a benefit of the prison's privilege system by reason of his disability; plaintiff also stated a claim under Title V of the ADA which prohibits retaliation for assertion of ADA rights; assessment of a strike under the PLRA is reversed.
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