Bennie Mae Snead v. Georgia Department of Corrections, et al.

Summary

The United States District Court for the Middle District of Georgia grants the Georgia Department of Corrections’ motion for summary judgment on claims under Title II of the Americans with Disabilities Act and § 504 of the Rehabilitation Act. The court concludes that the plaintiff failed to present evidence that prison officials had actual knowledge of a substantial likelihood of disability-based discrimination or were deliberately indifferent to such a risk.

Holdings

1. GDC was entitled to summary judgment because Snead failed to present sufficient evidence that a prison official with authority to institute corrective measures knew that Mincey faced harm to a federally protected right because of his hearing loss or failed to act despite that knowledge.
2. The alleged failure to follow GDC's reasonable-accommodation policy did not establish deliberate indifference because Snead failed to show that Mincey met the policy's criteria or that officials had subjective awareness of a disability-related risk of harm and failed to act.
3. Summary judgment is proper only when there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.

Questions Presented

1. Whether GDC was entitled to summary judgment on Snead's Title II ADA and § 504 Rehabilitation Act disability-discrimination claims.
2. Whether the evidence created a genuine dispute that a prison official with authority to institute corrective measures had actual knowledge that Mincey faced a substantial likelihood of harm to a federally protected right because of his hearing loss and nevertheless failed to act.
3. Whether GDC's alleged failure to follow its reasonable-accommodation policy regarding single-occupancy cells established deliberate indifference.

Disposition

other