The U.S. Court of Appeals for the Third Circuit issued a split decision Tuesday in a disability rights case against Pennsylvania's prison system, affirming some claims while sending others back to the lower court for further review.
In *Alan Decker v. Pennsylvania Department of Corrections* (3d Cir. 2026), the appeals court ruled on claims brought by Alan Decker, a blind inmate who alleged discrimination in the state's halfway-house parole program. Circuit Judge Krause, writing for a three-judge panel, delivered a non-precedential opinion that addressed multiple federal disability law claims.
The case centers on Decker's allegations that he faced delayed parole placement in Pennsylvania DOC's halfway-house program due to his blindness. Decker brought claims under the Equal Protection Clause of the Fourteenth Amendment, Title II of the Americans with Disabilities Act, and Section 504 of the Rehabilitation Act.
The Third Circuit affirmed the U.S. District Court for the Western District of Pennsylvania's dismissal of Decker's equal protection claim. However, the appeals court found that the district court made an error when analyzing Decker's ADA and Rehabilitation Act claims, specifically noting that the lower court "mistook the program at issue" in its analysis.
As a result, the Third Circuit vacated the district court's ruling on the federal disability law claims and remanded the case for further proceedings. This means Decker's ADA and Rehabilitation Act claims will receive fresh consideration by the district court.
The case was originally filed in 2023 in the Western District of Pennsylvania under case number 3:23-cv-00144, with District Judge Stephanie L. Haines presiding. The matter was submitted to the Third Circuit under Local Appellate Rule 34.1(a), which allows for disposition without oral argument in certain cases.
The three-judge panel consisted of Circuit Judges Krause, Phipps, and Roth. The case was submitted for decision on Nov. 3, 2025, and the court issued its opinion on Jan. 15, 2026.
Decker's claims against the Pennsylvania Department of Corrections involved Secretary Laurel Harry and Deputy Secretary Michael Wenerowicz, who oversees the Office of Reentry. The Office of Reentry typically handles programs designed to help inmates transition back into the community, including halfway-house placements.
The Americans with Disabilities Act's Title II prohibits discrimination by public entities, including state prison systems, against individuals with disabilities. Section 504 of the Rehabilitation Act contains similar anti-discrimination protections for programs receiving federal funding. Both laws require reasonable accommodations for individuals with disabilities.
Parole halfway-house programs serve as transitional housing for inmates nearing release, allowing them to maintain employment and community ties while still under correctional supervision. For individuals with disabilities, equal access to such programs can be crucial for successful reentry into society.
The Third Circuit's decision to remand the disability law claims suggests the court found merit in Decker's allegations that the Pennsylvania DOC may have failed to provide appropriate accommodations or equal access to reentry programs. The court's finding that the district court misidentified the relevant program indicates the complexity of analyzing disability accommodations within correctional settings.
Equal protection claims under the Fourteenth Amendment require plaintiffs to demonstrate that they were treated differently from similarly situated individuals based on their membership in a protected class. The Third Circuit's affirmance of the dismissal of this claim suggests Decker could not establish the necessary elements for constitutional relief.
The case highlights ongoing challenges faced by inmates with disabilities in accessing prison programs and services. Federal disability laws apply to correctional facilities, requiring prisons to provide reasonable accommodations and equal access to programs, services, and activities.
Pennsylvania's Department of Corrections, like other state prison systems, must balance security concerns with legal obligations to provide disabled inmates with equal opportunities for rehabilitation and reentry programming. The outcome of this case on remand could influence how the state approaches disability accommodations in its correctional facilities.
The opinion was marked as non-precedential, meaning it does not establish binding legal precedent for future cases. However, the decision provides guidance on how courts should analyze disability discrimination claims in correctional settings.
The case will now return to Judge Haines in the Western District of Pennsylvania for reconsideration of Decker's ADA and Rehabilitation Act claims. The district court will need to conduct a fresh analysis of whether Pennsylvania's DOC violated federal disability laws in its handling of Decker's halfway-house placement.
This ruling represents part of broader litigation addressing disability rights within correctional systems nationwide, as courts continue to interpret the scope of federal disability protections for incarcerated individuals.