Pennsylvania v. Yeskey

The Respondent, Yeskey, brought this claim against Pennsylvania’s Department of Corrections alleging that his exclusion from a prison Motivational Boot Camp because of his medical history of hypertension violated the Americans with Disabilities Act of 1990 (ADA). ADA Title II prohibited a “public entity” from discriminating, excluding or denying benefits to a “qualified individual with a disability,” with respect to “programs, services, or activities,” on account of that disability.

Yeskey was sentenced to 18 to 36 months in a Pennsylvania correctional facility, but was recommended for placement in the Motivational Boot Camp for first-time offenders, the successful completion of which would have led to Yeskey’s parole in just 6 months.

The District Court dismissed the case for failure to state a claim, finding the ADA inapplicable to State prison inmates. The Court of Appeals for the Third Circuit reversed that decision and this appeal followed.

The Court examined whether the ADA was applicable to State prison inmates. The Court held that “State prisons [fell] squarely within Title II's statutory definition of public entity, which include[d] any department, agency, special purpose district, or other instrumentality of a State or States or local government.” The Court also examined the ADA’s legislative intent and held that there was “no ambiguous exception” that rendered the coverage of the ADA to State prison inmates uncertain.

The Court rejected the Appellant’s claim that under the ADA “benefits” of programs and the term “qualified individual” were not intended to cover prison inmates. The Court explained that modern prison “programs, services, or activities,” such as those of the Pennsylvania correctional facility, did indeed provide inmates with “benefits,” even though the inmates were held against their will. The Court added that excluding an inmate from such “programs, services, or activities” restricted “qualified” inmates within that term’s meaning under the ADA.

“Assuming, without deciding, that the plain-statement rule does govern application of the ADA to the administration of state prisons, we think the requirement of the rule is amply met: the statute's language unmistakably includes State prisons and prisoners within its coverage. The situation here is not comparable to that in Gregory. There, although the ADEA plainly covered state employees, it contained an exception for "`appointee[s] on the policy making level' " which made it impossible for us to ‘conclude that the statute plainly cover[ed] appointed state judges."’501 U. S.,at 467. Here, the ADA plainly covers state institutions without any exception that could cast the coverage of prisons into doubt.” 542 U.S., p. 209.

“Petitioners contend that the phrase ‘benefits of the services, programs, or activities of a public entity,’ § 12132, creates an ambiguity, because state prisons do not provide prisoners with ‘benefits’ of ‘programs, services, or activities’ as those terms are ordinarily understood. We disagree. Modern prisons provide inmates with many recreational ‘activities,’ medical ‘services,’ and educational and vocational ‘programs,’ all of which at least theoretically ‘benefit’ the prisoners (and any of which disabled prisoners could be ‘excluded from participation in’).” 542 U.S., p. 210.