Gregory Allen v. Washington State Department of Corrections, Sgt. Jason Kaehler, and Does 1-10

Summary

The United States District Court for the Western District of Washington denied Gregory Allen’s motion for reconsideration of an order granting summary judgment to the Washington State Department of Corrections and Sgt. Jason Kaehler. The court held that Allen’s additional evidence was not new, that the ADA did not require the Department to provide him a single cell, and that Kaehler was entitled to qualified immunity on Allen’s wheelchair-related claim. The case remained closed.

Holdings

1. Reconsideration was not warranted because the evidence was available to Allen before the court's summary-judgment ruling and therefore was not new evidence.
2. The prior ruling that the ADA did not require DOC to provide Allen a single cell was not manifest error, and reconsideration was denied.
3. Kaehler remained entitled to qualified immunity because Allen did not identify a robust consensus of persuasive authority clearly establishing an unqualified right to a wheelchair in the alleged circumstances.

Questions Presented

1. Whether Allen established manifest error, newly discovered evidence, or another recognized basis for reconsideration of the summary-judgment order.
2. Whether the additional exhibits constituted new evidence warranting reconsideration.
3. Whether the court erred in concluding that the ADA did not require DOC to provide Allen a single cell.
4. Whether the court erred in concluding that Kaehler was entitled to qualified immunity on Allen's § 1983 wheelchair-access claim.

Disposition

other