Background
Matthew Wright, a Washington state prisoner, sued the State of Washington, the Department of Corrections, and individual employees. He alleged retaliation for filing grievances, denial of reasonable accommodations for reading difficulties under the Americans with Disabilities Act and the Rehabilitation Act, and negligence regarding his medical care and transfer decisions.
The court’s reasoning
The court reviewed the district court’s grant of summary judgment de novo. Regarding the First Amendment claim, the court found no clearly established law protecting duplicative and frivolous grievances as protected conduct. For the disability claims, the court determined that providing a workbook at the plaintiff’s reading level was a reasonable accommodation, and the plaintiff failed to prove a violation of the Americans with Disabilities Act. On the negligence claim, the court held that the plaintiff failed to present evidence, including expert testimony, establishing the applicable standard of care or a gross deviation from ordinary care.
What it means going forward
The ruling reinforces that correctional officials are shielded from liability when inmates file repetitive or baseless grievances and clarifies the evidentiary burden required to prove negligence in medical care disputes within state prisons.