Pennsylvania Dept. of Corrections v. Yeskey (1998)

By: Kacie Matthews

Overview

Pennsylvania Dept. of Corrections v. Yeskey, 524 U.S. 206 (1998) was a Federal level Supreme Court Case that resulted in a violation of the Americans with Disabilities Act (ADA) of 1990. The ADA prohibits discrimination against individuals with disabilities in areas like public services, employment, and accommodations. After Ronald Yeskey was recommended for placement within a Motivational Bootcamp due to his first time offense, the Bootcamp refused and rejected his admission to the facility due to his medical history, which in turn violated the Americans with Disabilities Act of 1990.

Summary

Ronald Yeskey had been charged with crimes of: 1) Driving under the influence, 2) Escaping Officers, and 3) Resisting Arrest. Yeskey had been charged with 18 to 36 months within the Pennsylvania Correctional Facility. As Yeskey was being sentenced, the judge recommended Yeskey apply for the Motivational Bootcamp, as he had been a first time offender. With successful completion of the Motivational Bootcamp, Yeskey could have gained early parole, as his prison sentence would have been decreased to just six months. When Yeskey applied to the Motivational Bootcamp, he was ultimately refused admission due to his medical history of hypertension (high blood pressure). Therefore, although Yeskey was a first time offender, and was an eligible candidate for the Motivational Bootcamp which would have benefited his prison sentence, he was forced to serve a much longer prison sentence. 

Yeskey filed a lawsuit against the Commonwealth of Pennsylvania's Department of Corrections, as he claimed that he was being medically excluded and discriminated against, which violated the ADA. More specifically, Yeskey mentioned that Title II of the ADA was being ignored, as such title issues a prohibition of public entities from discriminating against a qualified individual with disability. Although there were many filed claims on Yeskey’s behalf, they were all dismissed as the district court claimed that the ADA doesn’t apply to state inmates in prison. The District Court additionally claimed that the ADA covers inclusiveness and the same rights for those who are volunteering to be in specific situations, not those who are being held against their will, as in this scenario for a state prisoner. Lastly, District Courts argued that a state prison does not qualify as a public entity, and therefore doesn’t follow the ADA.

The mentioned decision of the ADA being inapplicable to state prison inmates led Yeskey to appeal the decision. As a result, the United States Court of Appeals for the Third Circuit reversed the District Court decision, and sided with Yeskey. The Third Circuit Court decided that prisons do fall under the regulated definition of “public entity” within the ADA. This decision was subsequently affirmed by the U.S. Supreme Court. Following the ruling that prisons need to comply with the ADA, Yeskey’s case was to be re-determined within the lower court. The lower court decided that his medical condition of hypertension didn’t limit his way of life, and his condition did not fall under a “disability” according to the ADA. Yeskey’s lawsuits were dismissed. 

Impact

Although Yeskey’s lawsuits were ultimately dismissed by the lower court, his appeal led the U.S. Supreme Court to determine that the Americans with Disabilities Act of 1990 applies to state prisons and inmates. The decision of Pennsylvania Dept. of Corrections v. Yeskey, 524 U.S. 206 (1998) clarified the regulations and definitions of “public entities” and “disabilities” under Title II of the ADA, and the understanding of who is covered by the ADA.

Court Documents

Pennsylvania Dept. of Corrections v. Yeskey, 524 U.S. 206 (1998), Justia, https://supreme.justia.com/cases/federal/us/524/206/

Citations

Pennsylvania Dept. of Corrections v. Yeskey, Oyez,  https://www.oyez.org/cases/1997/97-634

Pennsylvania Dept. of Corrections v. Yeskey, Cornell Law School, https://www.law.cornell.edu/supremecourt/text/97-634