Castle v. Eurofresh, Inc., No. 11-17947 (9th Cir. 2013)
Annotate this CasePlaintiff, a former Arizona state prisoner, filed suit against defendants, alleging that they violated the Americans with Disabilities Act (ADA), 42 U.S.C. 12131-12134, and the Rehabilitation Act of 1973 (RA), 29 U.S.C. 794, by failing to reasonably accommodate his disability. Plaintiff picked tomatoes for Eurofresh as a part of a convict labor force. The court concluded that plaintiff's claims against Eurofresh were properly dismissed because plaintiff and Eurofresh were not in an employment relationship, and Eurofresh did not receive federal financial assistance. The court concluded, however, that judgment was improperly granted to the State Defendants where they were liable for disability discrimination committed by a contractor. Accordingly, the court affirmed in part, reversed in part, and remanded to the district court to determine in the first instance whether such discrimination occurred.
Court Description: Prisoner Civil Rights. The panel affirmed in part and reversed in part the district court’s summary judgment and remanded in an action brought by an Arizona state prisoner who alleged that defendants violated the Americans with Disabilities Act, 42 U.S.C. §§ 12131–12134, and the Rehabilitation Act of 1973, 29 U.S.C. § 794, by failing to reasonably accommodate his disability at a prison job. The panel held that plaintiff’s claims against Eurofresh, a private company that contracted with the Arizona Correctional Industries for a convict labor force, were properly dismissed. The panel held that plaintiff was not Eurofresh’s “employee” under Title I of the ADA because his labor belonged to the State of Arizona, which put him to work at Eurofresh in order to comply with its statutory obligations. The panel further held that because Eurofresh did not receive federal financial assistance, either directly or indirectly, it was not subject to the requirements of the Rehabilitation Act. The panel reversed the judgment in favor of the State Defendants because it determined that those defendants could be held liable for acts of disability discrimination committed by Eurofresh, its contractor. The panel stated that the law was clear—State Defendants may not contract away their obligation to comply with federal discrimination law. The panel remanded to the district court to determine in the first instance whether any such discrimination occurred. Concurring, Judge Berzon stated that this circuit’s precedent compelled the conclusion that plaintiff was not an employee under Title I of the ADA. Judge Berzon stated that the notion that prisoners who work for covered employers can never be “employees” for purposes of federal employee- protective statutes undermines those statutes as applied to employees generally and misconstrues the reach of the “employee” designation.
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