Pennsylvania Department of Corrections v. Yeskey

Background

Ronald Yeskey, an inmate in a Pennsylvania correctional facility, was sentenced in May 1994 to 18–36 months. The sentencing court recommended the state Motivational Boot Camp, which could have led to parole after six months, but Yeskey was refused admission because of hypertension. He sued the Pennsylvania Department of Corrections and officials under Title II of the Americans with Disabilities Act. A federal district court dismissed his claim, the Third Circuit reversed, and the Supreme Court reviewed the question of statutory coverage.

Reasoning

The Court addressed whether Title II of the ADA covers state prisons and prisoners. Assuming, for argument’s sake, that a clear statement is required when federal law reaches core state functions, the Court found the ADA’s text plain and unambiguous. The statute defines a “public entity” to include state agencies, and its references to “services, programs, or activities” encompass medical care, educational and rehabilitative programs, and recreational activities that prisons provide. The Court also held that the definition of a “qualified individual with a disability” can apply to inmates and rejected the argument that “eligibility” or “participation” require voluntariness in every context.

Real world impact

Because the ADA’s text covers prisons, disabled inmates can bring ADA claims when excluded from prison programs, services, or activities and may seek reasonable modifications or aids to participate. The decision affirms the Third Circuit and requires prison systems to account for the ADA when administering programs like boot camps, medical services, libraries, education, and rehabilitation. The Court did not decide whether applying the ADA to States is a constitutional exercise of Congress’s power, leaving that constitutional question unresolved.