Brown v. Meisner, et al.
7th Cir. No. 22-2458
After injuring his knee in a fall at one Wisconsin prison, Lee Brown was transferred to another facility where his previously granted accommodations—a lower bunk, a wheelchair, and crutches—were not continued. He fell again while climbing to a top bunk, and was told he needed surgery that the prison would not provide. When Mr. Brown formally requested reasonable accommodations for his knee, prison officials denied the request, apparently concluding that his injury did not constitute a disability.
The district court dismissed his ADA claim, concluding that he had alleged only inadequate medical treatment rather than a failure to accommodate. The Seventh Circuit vacated that dismissal and remanded, holding that Mr. Brown's allegations gave fair notice of a failure-to-accommodate claim and that such a claim is distinct from one for medical malpractice.
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