The U.S. Court of Appeals for the Eleventh Circuit affirmed a lower court's decision to grant summary judgment in favor of Georgia county sheriffs in a disability discrimination case involving a legally blind inmate.
Kevin Lewis, who is legally blind, filed suit against Chatham County Sheriff John Wilcher and Fulton County Sheriff Patrick Labat after experiencing what he characterized as discrimination during his detention in both facilities. The case, *Lewis v. Sheriff, Fulton County Georgia* (11th Cir. 2026), addresses the scope of disability accommodations required under federal law in short-term detention settings.
Lewis was arrested on an outstanding warrant and detained at two Georgia county jails. His stay at the Chatham County jail lasted less than 48 hours, while his detention at the Fulton County jail extended approximately 16 days. During both detentions, Lewis alleged he was denied essential accommodations for his visual impairment.
According to court documents, Lewis requested assistance with reading documents, navigating the jail facilities, accessing the grievance process, and obtaining desired medications. He also sought accommodations for using jail telephones and electronic kiosks, which are standard equipment in modern correctional facilities for inmate communication and services.
The case centers on violations of two key federal disability rights statutes. Lewis brought claims under Section 504 of the Rehabilitation Act and Title II of the Americans with Disabilities Act (ADA). Both laws prohibit discrimination against individuals with disabilities by entities that receive federal funding or provide public services.
Section 504 of the Rehabilitation Act, enacted in 1973, was the first major federal civil rights law protecting the rights of people with disabilities. It prohibits discrimination in programs that receive federal financial assistance. Title II of the ADA, passed in 1990, extends these protections more broadly to state and local government services, programs, and activities, regardless of whether they receive federal funding.
Lewis sought both monetary damages and injunctive relief through his lawsuit. Monetary damages would compensate him for any harm suffered due to the alleged discrimination, while injunctive relief would require the sheriffs to change their policies and procedures to better accommodate inmates with disabilities in the future.
The defendants in the case included not only the individual sheriffs but also Fulton County and Chatham County as governmental entities. This dual approach is common in civil rights litigation, as plaintiffs often sue both individual officials and their employing agencies to ensure comprehensive relief and accountability.
The U.S. District Court for the Northern District of Georgia initially handled the case and granted summary judgment in favor of all defendants. Summary judgment is appropriate when there are no genuine disputes of material fact and the moving party is entitled to judgment as a matter of law. The district court apparently concluded that the sheriffs' actions did not violate federal disability rights laws.
Lewis appealed the district court's decision to the Eleventh Circuit, which has jurisdiction over federal appeals from Georgia, Florida, and Alabama. The three-judge panel that heard the case consisted of Circuit Judges Jill Pryor, William Pryor Jr., and Barbara Lagoa.
Circuit Judge Jill Pryor authored the opinion for the court. Judge Pryor, who was appointed to the Eleventh Circuit in 2014, has extensive experience in civil rights law from her previous work as a federal prosecutor and in private practice.
The appeals court conducted a careful review of the case and heard oral arguments before reaching its decision. Oral arguments provide an opportunity for attorneys to present their positions directly to the judges and answer questions about legal and factual issues in the case.
The Eleventh Circuit's affirmance of the district court's summary judgment ruling represents a setback for disability rights advocates who argue that correctional facilities must provide reasonable accommodations to inmates with disabilities, regardless of the length of their detention.
The case highlights ongoing challenges faced by individuals with disabilities in the criminal justice system. Jails and prisons must balance security concerns with their obligations under federal disability rights laws to provide equal access to programs, services, and facilities.
The distinction between short-term and long-term detention may have influenced the court's analysis. While Fulton County detained Lewis for approximately two and a half weeks, his stay at Chatham County was brief. Courts sometimes consider the duration of detention when evaluating what accommodations are reasonable and necessary.
The published nature of this opinion means it will serve as binding precedent within the Eleventh Circuit for future cases involving similar issues. Published opinions carry more weight than unpublished decisions and help establish legal standards that lower courts must follow.
This decision may impact how county jails throughout the Eleventh Circuit approach disability accommodations, particularly for inmates with visual impairments. Correctional administrators will likely review their policies in light of this ruling to ensure compliance with federal disability rights requirements while maintaining security protocols.