Muhammad v. California Department of Corrections and Rehabilitation

Background

Kwesi Muhammad filed this action in Monterey County Superior Court based on alleged violations at the Correctional Training Facility. He asserted claims under Title II of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act of 1973, naming only the California Department of Corrections and Rehabilitation as the defendant. The department removed the case to federal court.

Muhammad alleges that he has physical impairments in his hands and wrists from severe bilateral carpal tunnel syndrome. He says that, in October 2023, the facility’s Americans with Disabilities Act coordinator denied his request for accessible faucet controls in his cell. According to the complaint, the two push controls on his sink require more than five pounds of force and must be held continuously to keep the water running. Muhammad says he uses the sink for brushing his teeth, washing his hands, performing religiously required ablutions for five daily prayers, and cleaning his cell. He seeks injunctive relief and monetary damages.

Screening analysis

The court explained that federal law requires an initial screening of a prisoner’s case seeking relief from a governmental entity or its employees. During screening, the court identifies claims that may proceed and dismisses claims that are frivolous, malicious, inadequately pleaded, or seek money from an immune defendant. The court also stated that self-represented pleadings must be read liberally.

The court described the elements of an ADA Title II claim as requiring a disability, qualification to receive a public entity’s services or benefits, exclusion or discrimination involving those services or benefits, and a connection between that exclusion or discrimination and the disability. The court stated that a Section 504 claim generally has the same basic requirements. It also explained that the public entity responsible for the alleged discrimination—such as the department named here—is the proper defendant for these claims.

Ruling and schedule

The court GRANTS the motion to screen the complaint under 28 U.S.C. § 1915A. It concludes that, when read liberally, Muhammad’s complaint states a cognizable claim against the department under Title II of the Americans with Disabilities Act and Section 504. This ruling allows those claims to proceed past the initial screening; it does not decide the ultimate merits of the claims.

The department must answer within 28 days of the order. Within 60 days after the answer is due, it must file a motion for summary judgment or another dispositive motion unless it informs the court that summary judgment cannot resolve the case. Muhammad’s opposition is due 28 days after such a motion, and the department’s reply is due 14 days after the opposition. The order also permits discovery, including the department’s deposition of Muhammad and other necessary witnesses confined in prison, and reminds Muhammad to prosecute the case, keep the court informed of address changes, and comply with deadlines.