## Facts

- Ronald R. Yeskey, a Pennsylvania state inmate, was sentenced to 18 to 36 months’ imprisonment.
- The sentencing court recommended placement in a Motivational Boot Camp for first-time offenders; completion could have made him eligible for parole after six months.
- Prison officials denied him admission because of a medical history of hypertension.
- Yeskey sued the Pennsylvania Department of Corrections and officials, alleging disability discrimination under Title II of the Americans with Disabilities Act (ADA).
- The district court dismissed for failure to state a claim, ruling Title II did not apply to inmates; the Third Circuit reversed.

## Issues

1. Whether Title II of the ADA applies to inmates in state prisons.
2. Whether prison offerings such as a motivational boot camp are “services, programs, or activities” of a “public entity” covered by Title II.

## Decision

- The Supreme Court unanimously affirmed the Third Circuit.
- The Court held that state prisons are “public entities” within Title II’s definition and that the statute covers inmates and prison programs.
- The Court rejected arguments that Title II’s references to “benefits,” “programs,” and “qualified” participants exclude prisons.
- The Court declined to narrow the statute based on constitutional-avoidance principles because the statutory text was unambiguous.
- The case was remanded; the Court did not decide whether Yeskey’s exclusion actually violated the ADA on the merits.

## Legal Principles

- Title II applies to “any State or local government” and any “department, agency, or other instrumentality” of a State or local government; state prisons fall within this definition.
- When statutory coverage is clear, courts do not require additional clarification to include state prisons, even assuming heightened clarity concerns for traditional state functions.
- Prison recreational activities, medical services, and educational or vocational offerings qualify as “services, programs, or activities” that may “benefit” inmates for Title II purposes.
- The constitutional-doubt canon applies only when a statute is genuinely susceptible to more than one plausible construction; it does not justify rewriting unambiguous text.

## Conclusion

The Court held that Title II of the ADA unambiguously covers state prisons and the programs, services, and activities they provide, allowing inmates to invoke Title II protections when excluded from such programs because of disability.


Pennsylvania Dep’t of Corr. v. Yeskey, 524 U.S. 206 (1998)