Court Opinions: 10th Circuit Court of Appeals Opinion for Aug. 25

The 10th Circuit Court of Appeals

Editor’s Note: Law Week Colorado edits court opinion summaries for style and, when necessary, length.

Williams v. Colorado Department of Corrections

Charles Lamont Williams is a prisoner in the custody of the Colorado Department of Corrections at the Buena Vista Correctional Complex. Williams suffers from medical conditions that cause pain and make it difficult for him to walk, stand and bend. The Buena Vista medical staff issued work restrictions for him, like no standing more than two hours and no repetitive bending at the waist. 

In September 2019, a Buena Vista officer assigned Williams to kitchen duty. Williams believed his medical restrictions prevented him from successfully performing kitchen tasks and he raised that issue through communications with his case manager and through grievances, but received no reassignment or accommodation. He showed up for kitchen duty with his restriction list in hand. The kitchen staff looked at the list, decided he couldn’t perform the necessary tasks, and excused him back to his cell. This became a daily ritual for two weeks, after which kitchen staff, upon his arrival, stopped looking at his restriction list and sent him back to his cell. 

On Sept. 23, Williams was feeling particularly severe back pain. Rather than showing up for kitchen duty and being sent back to his cell, he put in a request for a medical appointment, confident that medical staff would excuse him from work that day. His prediction was correct. “[S]everal hours later,” a medical staff member gave him permission to stay in his cell.

Three days later, a Buena Vista officer submitted a grievance against Williams for failing to report for kitchen duty on Sept. 23, and fired Williams from his kitchen assignment. The grievance prompted CDOC to place Williams at a stricter security level, meaning he lost privileges and autonomy. Williams filed his own grievance against this and received a response from a CDOC official stating he had been disciplined for an unexcused failure to show up at work because medical staff didn’t excuse his absence until later in the day. 

The district allowed Williams to proceed without liability for the cost of the suit. A magistrate judge at the district court that first looked at the amended complaint recommended the complaint be dismissed as frivolous. The magistrate judge reasoned that Williams failed to “allege facts that demonstrate he was fired from his prison job or reclassified because of his disability,” and even then, “the ADA and the Rehabilitation Act do not apply to issues of prison employment.” 

Williams objected, but the district court adopted the recommendation without elaboration and dismissed the amended complaint as frivolous. Williams appealed. 

According to the 10th Circuit Court of Appeals, the district court incorrectly concluded the  ADA and Rehabilitation Act didn’t apply to prison employment matters and that Williams’ claim was “indisputably meritless.” 

The 10th Circuit reversed the district court decision and remanded the case.

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