Castle v. Eurofresh, Inc.

A prisoner of the state is not the “employee” of a company contracting with a state prison under Title I of the Americans with Disabilities Act, because the prisoner’s labor belongs to the state; further, where such a contracting company receives no direct or indirect federal financial assistance, the company is not subject to the requirements imposed by the Rehabilitation Act of 1973; however, a state may be held liable for disability discrimination acts that its contractors commit.

William Castle was an inmate in the Arizona state prison system. All able-bodied inmates are required to work at least forty hours per week under Arizona state law. Arizona Correction Industries runs a labor program, through which private companies contract for a convict labor force. Eurofresh, a greenhouse operation, participates in the convict labor program. Castle worked at Eurofresh picking tomatoes, which required him to be on his feet for seven hours a day and push a tomato cart often weighing 600 pounds. While working at Eurofresh, Castle re-aggravated a serious injury to his ankle that he had suffered many years earlier. Castle spoke with his supervisor and medical providers before sending a certified letter to Eurofresh asking for a position change. He was eventually told that no other positions were available to convicts, and his only option was to quit. Castle brought suit after filing a discrimination claim with the Equal Employment Opportunity Commission. Castle alleged that Eurofresh and other state defendants (“Defendants”), by failing to reasonably accommodate his disability, had violated his rights under Section 504 of the Rehabilitation Act of 1973 (“RA”) and Titles I and II of the Americans with Disabilities Act (“ADA”). The district court granted summary judgment for Defendants. Castle appealed. The Ninth Circuit held that, because the state of Arizona owned Castle’s labor, having given Castle the work to satisfy statutory obligations, Castle was not the “employee” of Eurofresh under Title I of the ADA. The panel further held that because Eurofresh received no direct or indirect federal financial assistance, the company was not subject to the requirements imposed by the RA. Finally, the panel held that the state defendants could not contract away their duty to comply with federal discrimination laws. AFFIRMED IN PART, REVERSED IN PART, AND REMANDED.