Jack Campbell v. Kootenai County Jail

Summary

The United States District Court for the District of Idaho screened Jack Campbell’s prisoner civil rights complaint against the Kootenai County Jail. The court permitted Campbell to proceed on an Americans with Disabilities Act claim concerning the alleged lack of a handicap-accessible shower, while dismissing his other ADA, due process, and free exercise claims. The court also denied Campbell’s motion for appointment of counsel and issued service and case-management instructions.

Holdings

1. The complaint plausibly stated a colorable ADA claim that Campbell was denied adequate shower facilities because of his disability, and he could proceed on that claim.
2. The complaint did not plausibly state ADA claims based on Campbell's placement in the medical pod or his resulting lack of access to religious and recovery programs.
3. The complaint did not plausibly state a § 1983 due process claim based on placement in the medical pod or administrative segregation.
4. The complaint did not plausibly state a First Amendment Free Exercise claim based on Campbell's inability to attend church or Bible study.
5. Appointment of counsel was denied because exceptional circumstances were not shown.

Questions Presented

1. Whether the complaint plausibly stated an ADA Title II claim based on the alleged failure to provide safe access to a handicap-accessible shower.
2. Whether the complaint plausibly stated ADA claims based on Campbell's placement in the medical pod and inability to attend religious or recovery programs.
3. Whether the complaint plausibly stated a 42 U.S.C. § 1983 due process claim based on placement in the medical pod or administrative segregation.
4. Whether the complaint plausibly stated a First Amendment Free Exercise Clause claim based on the denial of access to church and Bible study.
5. Whether exceptional circumstances warranted appointment of counsel in the civil case.

Disposition

other