In Armstrong v. Schwarzenegger, 622 F.3d 1058 (9th Cir. 2010), the Court rejected the State of Californias argument that it could not be held liable for ADA violations committed by county jails that were housing state prisoners pursuant to contracts with the state. The Court found it wholly irrelevant that the ADA violations occurred at county jails, rather than at state prisons under Californias immediate control. Rather, the Court clarified that Title IIs obligations apply to public entities regardless of how those entities chose to provide or operate their programs and benefits. See id. at 1065 (A public entity, in providing any aid, benefit, or service, may not, directly or through contractual, licensing, or other arrangements, discriminate against individuals with disabilities. (quoting 28 C.F.R. 35.130(b)(1)).