Pa. Dep't of Corr. v. Yeskey - 524 U.S. 206, 118 S. Ct. 1952 (1998)

Rule:

The Americans with Disabilities Act, 42 U.S.C.S. § 12131 et seq., defines "qualified individual with a disability" to include anyone with a disability who, with or without reasonable modifications to rules, policies, or practices, the removal of architectural, communication, or transportation barriers, or the provision of auxiliary aids and services, meets the essential eligibility requirements for the receipt of services or the participation in programs or activities provided by a public entity. 42 U.S.C.S. § 12131(2).

Facts:

Respondent prisoner was eligible for the Pennsylvania Motivational Boot Camp under Pa. Stat. Ann. tit. 61, § 1121 et seq. (Supp. 1998). However, petitioner corrections department refused his admission to the program due to his hypertension. Respondent brought an action challenging petitioner's denial of his access to the boot camp as a violation of the Americans with Disabilities Act (ADA), 42 U.S.C.S. § 12131 et seq. The trial court held that the ADA was inapplicable to inmates in state prisons. The Court of Appeals reversed the trial court’s decision. Petitioner sought review of the decision, claiming that it and the program were not governed by the ADA.

Issue:

1. Was the ADA applicable to state prisons? 
2. Was the petitioner’s denial of respondent prisoner’s access to the boot camp violative of the ADA?

Answer:

1) Yes. 2) Yes.

Conclusion:

The Court affirmed the lower court's reversal of the trial court, holding that the ADA was applicable to state prisons, because the plain language of the ADA unambiguously extended to state prison inmates; and thus, even assuming that the "plain statement" rule, which required an unmistakably clear expression of legislative intent before a statute would be interpreted as destroying a state's substantial sovereign powers, was applicable in this context, the ADA met that requirement. Furthermore, the Court held that the boot camp was an ADA-protected voluntary program by virtue of its definition in Pa. Stat. Ann., tit. 61 §§ 1123, 1126(a) (Supp. 1998).