Trump Judge Fails to Consider Prisoner’s Claim Under Americans with Disabilities Act
“Confirmed Judges, Confirmed Fears” is a blog series documenting the harmful impact of President Trump’s judges on Americans’ rights and liberties. It includes judges nominated in both his first and second terms.
What’s at stake in this case?
Daniel Jackson, a state prisoner in Virginia, challenged the failure of officials to provide him with effective treatment of leg injuries and pain.
What happened in this case?
Prior to Jackson’s transfer to a corrections center in Augusta, his leg injuries and pain had been accommodated through a support sleeve for his ankle and a medically assigned bottom bunk. These accommodations were discontinued at Augusta despite numerous requests by him. He also did not receive prescribed physical therapy and some pain medication.
Acting without a lawyer, Jackson filed a federal court complaint. The form he used instructed him to state relevant facts and not to make legal arguments. The district court dismissed the complaint but, as his lawyer argued on appeal, considered only constitutional claims of deliberate indifference and did not consider whether the course of conduct violated his rights under the Americans with Disabilities Act (ADA).
On appeal, Trump judge Marvin Quattlebaum, joined by George W Bush judge Steven Agee, wrote a 2-1 decision affirming the decision below and dismissing Jackson’s case. Obama judge Henry Floyd dissented in the March 2026 ruling in Jackson v Dameron.
What was the rationale of Trump judge Quattlebaum and George W Bush judge Agee?
Quattlebaum and Agee ruled that the “essential grievance” of Jackson’s complaint was that prison officials were deliberately indifferent to his complaints and that it was not error for the district court to construe the complaint as raising only a constitutional claim.
Why did Judge Floyd dissent?
Judge Floyd criticized the failure of the district court and the court of appeals majority to consider whether the treatment received by Jackson violated the ADA. Jackson’s initial complaint, he explained, “clearly states a plausible claim for ADA injunctive relief,” but the lower court failed to “liberally construe” the complaint to include it. The court of appeals majority, he went on, “fails to hold the district court to the exacting standard” required by precedent. As a result, he concluded, the majority had failed to fulfill its “great responsibility” to safeguard the rights of “our most vulnerable citizens.” The case should have been remanded, he wrote, for “further proceedings” on Jackson’s ADA claim.
Why is the decision harmful?
The ruling by Trump judge Quattlebaum and George W Bush judge Agee obviously harms Daniel Jackson by denying him any relief for his ADA claims. It also sets a bad precedent in evaluating prisoner claims and the need to liberally construe claims made without a lawyer, particularly in the Fourth Circuit, which includes Virginia, Maryland, West Virginia, and North and South Carolina. The case also illustrates the importance of our federal courts to health, welfare and justice and the significance of having fair-minded judges on the federal bench.