Robert L. Emery, Jr. v. Oregon Department of Corrections (ODOC), an Agency of the State of Oregon; Oregon Corrections Enterprises (OCE), an Agency of the State of Oregon; Mr. Castanon, OCE Production Manager; Mr. Poppell, OCE Production Manager; Lori Hensel, OCE General Manager

Summary

The United States District Court for the District of Oregon granted defendants’ motion for summary judgment in an action brought by Robert L. Emery, Jr., an adult in custody, alleging violations of the Americans with Disabilities Act, the Rehabilitation Act, and the Equal Protection Clause. The court held that Emery was not otherwise qualified to perform the TRCI laundry position with his requested wheelchair accommodation and that the reassignment was rationally related to legitimate safety and productivity interests.

Holdings

1. Plaintiff was not otherwise qualified for the laundry position because he could not perform its essential standing requirements and failed to show that use of a wheelchair was a reasonable accommodation that would enable him to perform those requirements.
2. Plaintiff failed to establish intentional discrimination under the ADA or Rehabilitation Act because he was not denied the benefits of the prison's work programs and produced no evidence that Defendants acted with deliberate indifference to a federally protected right.
3. The reassignment did not violate the Equal Protection Clause because disability classifications receive rational-basis review, and the safety and productivity concerns supporting the wheelchair restriction were rationally related to legitimate correctional interests.

Questions Presented

1. Whether Plaintiff was otherwise qualified to perform the essential functions of the prison laundry position with or without the requested wheelchair accommodation under the ADA and Rehabilitation Act.
2. Whether prohibiting Plaintiff from performing the laundry position in a wheelchair constituted intentional disability discrimination under the ADA or Rehabilitation Act.
3. Whether reassigning Plaintiff from the laundry position violated the Equal Protection Clause of the Fourteenth Amendment.

Disposition

dismissed