Armstrong v. Brown, No. 12-17103 (9th Cir. 2014)
Annotate this CasePlaintiffs, a class of disabled state prisoners and parolees, filed suit seeking disability accommodations required by the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and the Rehabilitation Act (RA), 29 U.S.C. 701. On appeal, the State challenged a 2012 order where the district court modified the accountability provisions of an earlier injunction ordering the State to take specified steps to ensure that disabled inmates were provided with needed accommodations. The court rejected the State's contention that the injunction was issued without notice and an opportunity for it to respond; the State waived the arguments that the statewide scope of the Modified Injunction is unsupported by the evidence and that the Modified Injunction conflicts with various state laws and the Collective Bargaining Agreement (CBA); the evidence was insufficient to warrant systemwide relief and the court declined to exercise its discretion in considering such arguments; the Modified Injunction does not violate the Prison Litigation Reform Act (PLRA), 18 U.S.C. 3626; and the sections setting forth the expert witness' authority and duties, Sections D.2 and D.3, are invalid. Accordingly, the court affirmed in part, vacated in part, and remanded.
Court Description: Prisoner Civil Rights. The panel affirmed in part and vacated in part the district court’s order modifying the accountability provisions of an earlier injunction ordering the State of California to take specified steps to ensure that disabled inmates were provided with needed accommodations. The panel rejected the State’s contention that the Modified Injunction was issued without notice and an opportunity for it to respond. The panel further held that the State waived its challenge to the statewide scope of the injunction and also waived its argument that the injunction conflicted with state law and the Collective Bargaining Agreement between the State and prison employees. The panel declined to exercise its discretion to consider these arguments. The panel held that the Modified Injunction complied with the Prison Litigation Reform Act. The panel held that the district court did not err in finding that a modification to the accountability system was necessary because the State had failed to fulfill the accountability requirements mandated by its previous injunction to track inmates’ needs and ensure the receipt of needed accommodations. The panel determined that the Modified Injunction was narrowly tailored and no broader than necessary to address the federal violations. The panel held that the district court exceeded its authority in appointing an expert to resolve disputes between plaintiffs and the State because this delegation of authority was beyond the scope of the duties that may be assigned to an expert appointed pursuant to Federal Rule of Evidence 706. The panel therefore vacated that portion of the Modified Injunction and remanded to the district court with instructions to revise the Modified Injunction in a manner consistent with the panel’s opinion.
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