From the Courts: Americans with Disabilities Act; Deliberate Indifference; Prison Mental Health; Civil Contempt; Exhaustion of Remedies
Author: Ken Kozlowski.
Source: Volume 26, Number 03, Summer 2025 , pp.53-56(4)

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Abstract:
Our regular review of important appellate decisions includes three cases: McDaniel v. Syed (7th Cir. 2024), where the court revived an ADA/Rehabilitation Act claim because denying a “no-stairs” housing assignment effectively deprived an inmate of access to meals, medication, and programs, while affirming summary judgment on requests for a single cell, no top bunk, and on the Eighth Amendment claim; Coleman v. Newsom (9th Cir. 2025), which upheld civil contempt findings against California for persistent unconstitutional prison mental-health care but vacated fines to the extent they exceeded the State’s monthly salary savings and remanded for recalculation; and Butler v. Orenstein (7th Cir. 2024), affirming dismissal where untimely and noncompliant grievances meant the inmate failed to exhaust administrative remedies on a dental-care claim.Keywords: Americans with Disabilities Act; Deliberate Indifference; Prison Mental Health; Civil Contempt; Exhaustion of Remedies
Affiliations:
1: Contributing Editor.