Bennett v. Dart

Federal 7th Circuit Court
Civil Court
Class Action
Citation
Case Number: 
No. 22-8016
Decision Date: 
November 14, 2022
Federal District: 
N.D. Ill., E. Div.
Holding: 
Reversed and remanded

Dist. Ct. erred in decertifying class action under circumstances where class of disabled inmates who sought use of prison showers and toilets, but could not do so because said facilities lacked grab bars and other fixtures, had previously been certified. Dist. Ct. held belief that certification was not appropriate because some members of class, although using wheelchairs, might not be disabled within meaning of federal law. Ct. of Appeals, though, found that certification was appropriate, since class certification under Rule 23(c0(4) would only resolve legal issue as to whether said prison facilities require grab bars and other fixtures. As such, once instant legal issue has been resolved, Dist. Ct. can resolve whether each class member would be entitled to any relief. Also, Dist. Ct. failed to explain why application of Uniform Federal Accessibility Standards, which require accessible toilets and showers, could not be applied class-wide.