Craig v. CDCR

Background

Kent Craig, a prisoner representing himself, brought a civil-rights action for damages concerning his prison’s handling of a request for an Americans with Disabilities Act (ADA) accommodation. He requested a permanent lower-bunk assignment because he experienced hip and lower-back pain when climbing into an upper bunk and asserted that he had a disability related to his past military service. The court had allowed Craig’s claims under Title II of the ADA and Section 504 of the Rehabilitation Act to proceed.

Craig was temporarily assigned to a lower bunk while prison officials evaluated his request. Medical staff reviewed his records, scheduled medical appointments, and did not recommend a lower-bunk accommodation. The record stated that Craig could exercise, work in the prison bakery, climb stairs, walk steadily, rise from a chair, and get onto an elevated examination table. He also reported that several pain medications helped his hip pain. Craig declined an offer of physical therapy.

Motions and legal standard

Defendants moved for summary judgment under Federal Rule of Civil Procedure 56. Craig did not file an opposition; instead, he filed his own cross-motion for summary judgment. Summary judgment is appropriate when the evidence shows that there is no genuine dispute about a fact important to the outcome and the moving party is entitled to judgment under the law. The court considered factual statements in Craig’s amended complaint because he had signed it under penalty of perjury.

Court’s analysis

The ADA requires a plaintiff to show that he is a qualified individual with a disability, that he was excluded from or denied the benefits of a public entity’s services or otherwise discriminated against, and that the exclusion, denial, or discrimination occurred because of the disability. The court applied essentially the same analysis to Craig’s Rehabilitation Act claim.

The court agreed with defendants that Craig had not established the first requirement: that he was a qualified individual with a disability. Defendants presented evidence that Craig had not sought treatment for hip or back pain during the year before his accommodation request and that later evaluations did not show limitations on his major life activities.

Craig relied on a Veterans Administration letter stating that he had a disability from “invertebral disc syndrome.” The court found that the letter was insufficient because it was more than a decade older than the events in the case, did not explain the degree to which any major life activity was substantially limited, and did not establish that the condition was related to his hip pain. The court also noted that Veterans Administration disability compensation is based on reduced earnings capacity, which alone does not establish disability under the ADA or Rehabilitation Act.

Because Craig failed to rebut defendants’ evidence or identify a major life activity he could not perform, the court concluded that defendants were entitled to judgment as a matter of law.

Disposition

Judge Edward M. Chen granted defendants’ motion for summary judgment, denied Craig’s motion for summary judgment, entered judgment in defendants’ favor, directed the Clerk to close the file, and stated that the order disposed of Docket Nos. 39 and 40.