Muhammad v. California Department of Corrections and Rehabilitation

Background

Kwesi Muhammad sued the California Department of Corrections and Rehabilitation over alleged disability discrimination at the Correctional Training Facility. His claims arose under Title II of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act. He sought monetary damages.

Muhammad alleged that he had disabilities related to a left-knee meniscus repair and left-foot hammertoe correction. He claimed that, in April 2021, the department ended a practice of allowing certain prisoners with disabilities to shower at specified times after the 5:00 p.m. inmate count. He alleged that the prior practice was restored around September 2021.

Summary-judgment standard

The court applied Federal Rule of Civil Procedure 56. Summary judgment is appropriate when the evidence shows no genuine dispute over a fact that could affect the outcome and the moving party is entitled to judgment as a matter of law. After the moving party presents evidence supporting judgment, the opposing party must identify specific evidence showing a real dispute requiring a trial.

Court’s analysis

The court considered Muhammad’s ADA and Section 504 claims together because the parties had not identified a relevant difference between the two legal analyses.

First, the court held that Muhammad had not shown that he was a qualified individual with a disability during the relevant period. The department’s evidence showed that Muhammad had no disability-program code or verified disability in 2021. Medical records stated that his 2019 knee procedure had been successful, that he could go up and down stairs, and that later medical visits did not document mobility concerns. Muhammad did not identify a major life activity that he could not perform or that was substantially limited. The court also noted evidence that his request for special shower access arose from his desire to avoid showering with prisoners of another race, rather than from a disability-related need.

Second, the court held that, even assuming Muhammad had a qualifying disability, he could not show that he was excluded from or denied the benefits of the prison’s shower facilities because of that disability. The evidence showed that officers offered him access to the showers every other day, the same frequency offered to other prisoners on his tier. Muhammad declined those offers because he wanted to shower after the 5:00 p.m. count and in a particular order with other prisoners who had qualifying disability-program codes. The court concluded that his refusal to use the showers unless he received that priority access did not establish an ADA or Section 504 claim.

Disposition

Judge Araceli Martinez-Olguin granted the department’s second motion for summary judgment. The court found no genuine dispute of material fact on Muhammad’s disability-discrimination claims and directed the clerk to close the file.