Chisolm v. Manimon, 97 F. Supp. 2d 615, (3rd Cir (D.N.J.), May 2000)
http://lawlibrary.rutgers.edu/fed/html/ca95-991-1.html
Plaintiff’s ADA and 504 claims failed when the district court found that plaintiff was provided with reasonable accommodation while he was detained at a county correctional facility. A former deaf jail detainee sought injunctive relief against the warden of a county detention center for violation of ADA, 504 and state laws against discrimination, alleging lack of accommodation. Plaintiff, arrested because of an outstanding warrant, was brought to the county detention facility to await a hearing, where he spent four days. He alleged he was denied the use of a TTY, sign language interpreter services in the cell area and that closed captioning was not activated on the television set provided for detainees. Plaintiff also alleged violation of Section 1983, alleging that his right to due process was violated when he was mistakenly classified as a medium, rather than minimum, security inmate. Defendant's motion for summary judgment was granted: The warden directed that a TTY be purchased immediately and although a delay ensued, plaintiff was allowed to use his own TTY that was brought to the jail; allowing a sign language interpreter in the cell area would have compromised jail security; and closed captioning was available but plaintiff did not request to have it activated. Therefore, reasonable accommodation was provided and no violation occurred. The Section 1983 claim was denied because his erroneous classification did not cause him to suffer significant hardship and he was in no danger of future harm.