Pennsylvania Dept. of Corrections v. Yeskey

In Pennsylvania Dept. of Corrections v. Yeskey (1998) 524 U.S. 206, a court sentenced the plaintiff to serve time in a Pennsylvania correctional facility with a recommendation that the time be served in a motivational boot camp for first-time offenders which could result in early release. The Department of Corrections thereafter denied the plaintiff admission to the boot camp because of "his medical history of hypertension." (Id. at p. 208.) The plaintiff did not attempt to raise the ADA issue in the context of the criminal proceeding. Instead, he filed a civil complaint alleging the Department's decision to exclude him from the boot camp program violated the ADA. A unanimous United States Supreme Court ruled that "the statute's language unmistakably includes State prisons and prisoners within its coverage" (524 U.S. at p. 209), but nothing in its decision remotely suggests the ADA claim could have been asserted in the context of a criminal proceeding seeking to set aside the court's sentencing decision.