A Pennsylvania prison denied John Williams, a prisoner with neck and arm disabilities, the rigid neck brace, rigid wrist splints, and effective pain medication he needed to access prison services and activities. Absent these accommodations that immobilize his neck, hands, and wrists and manage his pain, Williams experiences debilitating pain that impedes, and at times entirely prevents, him from participating in various everyday activities like sleeping, eating, holding objects, opening doors, and cleaning himself.

Title II of the Americans with Disabilities Act (ADA) bars discrimination by public entities, providing that “no qualified individual with a disability shall, by reason of such disability, be excluded from participation in or be denied the benefits of the services, programs, or activities of a public entity, or be subjected to discrimination by any such entity.” That bar creates an affirmative obligation on public entities to provide accommodations that allow people with disabilities to meaningfully access public services, programs, and activities. The Supreme Court has repeatedly recognized that Title II’s nondiscrimination mandate applies to all public entities, including state prisons. And the statutory text is clear: medical care is a service under Title II.

Nonetheless, the district court below dismissed Williams’s failure-to-accommodate ADA claim because, it said, that claim was actually challenging inadequate medical treatment. Williams appealed, and in October 2026, CAC filed an amicus brief in the Third Circuit supporting his claim. Our brief makes three principal points.

First, there is no textual carveout that excludes prison medical care from Title II’s broad prohibition on disability discrimination. Second, even if there were such a carveout, Williams’s requests were interventions to accommodate his disabilities under Title II (and thus restore his access to prison services and activities), not medical treatment at all. Third, and finally, the district court erred in invoking a line of cases stemming from a 1996 Seventh Circuit decision, Bryant v. Madigan, which first posited an atextual, “judge-made” carveout for prison medical care. That carveout is plainly at odds with Title II’s broad statutory ban on discrimination in any public “service, program, or activity.”