Case: Hall v. Thomas

4:97-cv-00874 | U.S. District Court for the Southern District of Texas

Filed Date: March 18, 1997

Closed Date: 1999

Clearinghouse coding complete

Case Summary

On March 18, 1997, a federal inmate in state custody in Texas filed a lawsuit under 42 U.S.C. § 1983 and the Americans with Disabilities Act, 42 U.S.C. § 12111 et seq in the United States District Court for the Southern District of Texas, Houston Division. The plaintiff, represented by private counsel, asked the court for declaratory relief, injunctive relief and monetary damages, claiming that the defendants had exhibited a deliberative indifference to his medical condition and as such had vi…

On March 18, 1997, a federal inmate in state custody in Texas filed a lawsuit under 42 U.S.C. § 1983 and the Americans with Disabilities Act, 42 U.S.C. § 12111 et seq in the United States District Court for the Southern District of Texas, Houston Division. The plaintiff, represented by private counsel, asked the court for declaratory relief, injunctive relief and monetary damages, claiming that the defendants had exhibited a deliberative indifference to his medical condition and as such had violated his constitutional and statutory rights. Specifically, the Plaintiff claimed that when he entered the custody of the Defendants his initial medical screening health questionnaire was incorrectly completed in violation of policy. The Plaintiff asserted that as a result of the indifferent administration of the initial medical screening health questionnaire, he was incorrectly classified as not disabled which prevented him from receiving the accommodations he required. Plaintiff in fact has epilepsy, major depression, and a number of other disabling disorders. The Plaintiff was subsequently housed in the administrative segregation section, rather than in the hospital ward as he claimed was required by his medical condition. The Plaintiff contends that this initial misclassification upon entry into custody lead to 17 months of being housed in an incorrect unit without access to the proper accommodations he was entitled to as a disabled person. The Plaintiff claimed that the lack of proper accommodations led to excessive seizures and mental anguish. Furthermore, the Plaintiff claimed that the Defendants had been deliberately indifferent to his medical condition and failed to adequately treat the Plaintiff's chronic kidney disorder for 17 months, which had serious implications for his health in violation of the equal protection clause and the due process clause. Additionally, the Plaintiff claimed that the Defendants had breached their duty owed to the Plaintiff as a disabled person by compelling him to wear leg irons, despite their use having been restricted because of his orthopedic disability. Furthermore, the Plaintiff claimed that the defendants had failed to provide him with appropriate medical care to control his diabetes, which led to a partial loss of his vision. The Plaintiff further contended that as a result of his inadequate medical care and incorrect classification, he stood trial for a federal crime in a diminished mental and debilitative state in violation of his 5th, 6th, 8th and 14th Amendment rights.

On motion for summary judgment, the District Court first found that Congress did not intend for the Americans with Disabilities Act to apply to the treatment of prisoners within state prisons. Furthermore, the District Court found that the Defendants were entitled to qualified immunity as to the Plaintiff's ADA claim. Pursuant to the 11th Amendment, the District Court dismissed all of the Plaintiff's claims for damages against Defendants in their official capacities. On the Plaintiff's deprivation of medical care claims, the court held that o amount a constitutional deprivation of medical care, the acts or omissions must be "sufficiently serious to evidence deliberate indifference to serious medical needs." Negligent failure to supply medical care does not amount to a constitutional deprivation. Consequently, as to the Plaintiff's §1983 claims, the District Court held that Hall was not denied medical care and consistently received medical care throughout his incarceration, therefore even taken as true, the Defendant's acts and omissions did not amount to a constitutional deprivation of medical care. Therefore, the Plaintiff's §1983 claims were dismissed by the District Court. In the end, the District Court granted all of the summary judgment motions before it, and dismissed a number of claims for failure to state a claim.

On appeal to the 5th Circuit Court of Appeals, the Plaintiff argued that the District Court incorrectly granted the motions for summary judgment and the dismissals for failure to state a claim. On October 26, 1999, the 5th Circuit affirmed the District Court's orders but also held that the District Court had erred in holding that the ADA does not apply to prisoners incarcerated in state prisons. Nevertheless, though it held that the ADA applies to the Plaintiff while incarcerated in the County Jail, the 5th Circuit upheld the District Court's decision on grounds of qualified immunity because the Plaintiff failed to show that the Defendants had shown a deliberate indifference to his serious medical need.

Summary Authors

Justin Benson (4/13/2011)

People


Judge(s)

Benavides, Fortunato Pedro (Texas)

DeMoss, Harold R. Jr. (Texas)

Attorney for Plaintiff

Bevans, Thomas J (Texas)

Attorney for Defendant

Baker, Mary E (Texas)

Durham, Drew Taylor (Texas)

Expert/Monitor/Master/Other
Judge(s)

Benavides, Fortunato Pedro (Texas)

DeMoss, Harold R. Jr. (Texas)

Hoyt, Kenneth M. (Texas)

Politz, Henry Anthony (Louisiana)

Attorney for Plaintiff
Expert/Monitor/Master/Other

show all people

Documents in the Clearinghouse

Document

4:97-cv-00874

Docket

March 18, 1997

March 18, 1997

Docket
1

4:97-cv-00874

Plaintiff's Original Complaint

March 18, 1997

March 18, 1997

Complaint
35

4:97-cv-00874

Motion for Summary Judgment of Major Michael Quinn In his Individual Capacity

Aug. 28, 1997

Aug. 28, 1997

Pleading / Motion / Brief
36

4:97-cv-00874

Motion for Summary Judgment of Sheriff Tommy B. Thomas in his Individual Capacity

Aug. 29, 1997

Aug. 29, 1997

Pleading / Motion / Brief
45

4:97-cv-00874

Defendants Seale, Guice, Trinh, Phi, Luu, Chassay, and Klein's Motion for Summary Judgment and Brief in Support

Oct. 10, 1997

Oct. 10, 1997

Pleading / Motion / Brief
65

4:97-cv-00874

Memorandum Opinion

Jan. 16, 1998

Jan. 16, 1998

Order/Opinion

1998 WL 1998

4:97-cv-00874

Brief of Appellant

U.S. Court of Appeals for the Fifth Circuit

Sept. 4, 1998

Sept. 4, 1998

Pleading / Motion / Brief

1998 WL 1998

4:97-cv-00874

Defendant-Appellee's Letter Brief

U.S. Court of Appeals for the Fifth Circuit

Oct. 6, 1998

Oct. 6, 1998

Pleading / Motion / Brief

1998 WL 1998

4:97-cv-00874

98-20571

Appeal from the United States District Court for the Southern District of Texas

U.S. Court of Appeals for the Fifth Circuit

Sept. 29, 1999

Sept. 29, 1999

Order/Opinion

190 F.3d 190

Docket

Last updated March 27, 2024, 3:22 a.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: Texas

Case Type(s):

Prison Conditions

Special Collection(s):

Multi-LexSum (in sample)

Key Dates

Filing Date: March 18, 1997

Closing Date: 1999

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Federal inmate being detained in a county jail

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Sheriff Tommy B. Thomas (Harris), County

Case Details

Causes of Action:

42 U.S.C. § 1983

Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12111 et seq.

Constitutional Clause(s):

Due Process

Equal Protection

Cruel and Unusual Punishment

Available Documents:

Trial Court Docket

Complaint (any)

Any published opinion

Outcome

Prevailing Party: Defendant

Nature of Relief:

None

Source of Relief:

None

Issues

General:

Restraints : physical

Discrimination-basis:

Disability (inc. reasonable accommodations)

Medical/Mental Health:

Medical care, general

Type of Facility:

Government-run