Case Explained: Untitled Opinion

Court: United States Court of Appeals for the Tenth Circuit

Filed: 2026-06-02

Docket: 5:26-CV-04006-TC-ADM)

The Tenth Circuit affirmed the district court’s dismissal of Angeliina Lawson’s pro se civil rights action brought under 42 U.S.C. § 1983 and the Americans with Disabilities Act (ADA). The court applied a de novo standard of review, accepting well-pleaded factual allegations as true but disregarding conclusory statements that do not plausibly suggest entitlement to relief. The court held that Lawson failed to state a claim for ADA discrimination or retaliation because her complaint did not plausibly allege that she was denied access to a parenting report or other court services specifically because of her disability. The record indicated the denial was based on Kansas law classifying the document as non-public rather than on her status as an individual with a disability. Furthermore, the court found Lawson failed to state a claim for retaliation because she could not plausibly allege that being denied access to a nonpublic document constituted a “materially adverse” action or demonstrate a causal connection between her request for accommodation and the denial. Consequently, the judgment of the district court is affirmed, leaving the dismissal in place.

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