U.S. Court of Appeals for the Ninth Circuit
Adom v. California Department of Corrections and Rehabilitation
September 8, 2026
Summary
The Ninth Circuit reversed the district court’s summary judgment on the plaintiff’s Title II ADA claim, holding that a reasonable jury could find the inmate was a qualified individual with a disability, was denied meaningful access to toileting and hygiene services because of his disability, and that the denial was by reason of his disability. The court also found sufficient evidence of a triable issue of deliberate indifference and remanded for the district court to determine the plaintiff’s standing to seek a permanent injunctive accommodation. The Eighth Amendment claims were partially affirmed and remanded.