Munoz v. CDCR
9th Cir. No. 19-17292
Rights Behind Bars represents Rick Munoz in his appeal of the district court’s grant of summary judgment to the California Department of Corrections and Rehabilitation (CDCR) on his claim under the Americans with Disabilities Act (ADA). Munoz entered the custody of CDCR with a history of several major knee injuries, and the prison system provided him a “low-bunk chrono” to ensure that he did not have to climb up to a top bunk to sleep at night. A prison doctor, disbelieving the severity of his injuries, needlessly retracted his chrono, and the following day his knees locked climbing to his bed and he fell, tearing his ACL and meniscus. The district court granted summary judgement to the Defendants, holding that Munoz’s litany of medical evidence showing damaged knees did not qualify him as disabled under the ADA, but did so by mistakenly relying on outdated law. In 2008, Congress unanimously amended the ADA as a reaction to this exact situation: when patently unreasonable accommodations were being dismissed by courts by finding the plaintiffs insufficiently disabled. Congress broadened the definition of disability, articulating a lenient definition of disability which Munoz clearly meets.
The Ninth Circuit found that there were disputed material facts as to whether a doctor had conducted an adequate inquiry into Mr. Munoz’s disability, and reversed the district court’s summary judgement ruling and remanded the case.
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