A federal appeals court has reversed a lower court's decision in the case of Bilal Adom v. California Department of Corrections and Rehabilitation (CDCR), allowing Adom's claims under the Americans with Disabilities Act (ADA) to move forward. The ruling affects not only Adom, an inmate at Salinas Valley State Prison, but also sets a precedent for how prisons accommodate inmates with disabilities.
Adom, who suffers from spinal pain and incontinence, alleged that the CDCR failed to provide him with necessary medical supplies, specifically adult diapers, after he was transferred to a different housing unit. This lack of supplies led to significant distress and humiliation for Adom, who argued that the denial of these supplies violated his rights under the ADA.
The case began when Adom filed a pro se complaint in November 2022, asserting that the CDCR's actions constituted a failure to reasonably accommodate his disabilities. The district court initially granted summary judgment in favor of the CDCR, dismissing Adom's claims. However, Adom appealed the decision, and the Ninth Circuit heard the case on October 23, 2025.
In its ruling, the Ninth Circuit found that a reasonable jury could conclude that Adom was indeed disabled under the ADA and that he was denied meaningful access to the prison's toileting and hygiene services. The court stated, "A reasonable jury could conclude that Adom is disabled within the meaning of the ADA by virtue of his spinal condition, incontinence, or both." The panel also noted that the prison's failure to provide adult diapers for nearly five months could suggest deliberate indifference to Adom's needs.
The court emphasized that public entities, including prisons, have an obligation to provide reasonable accommodations for individuals with disabilities. The ruling highlighted that a public entity is not excused from its responsibility to provide accommodations simply because it determines that such accommodations are not medically necessary. The judges on the panel included Richard A. Paez, Carlos T. Bea, and Danielle J. Forrest.
The implications of this ruling are significant. It reinforces the legal requirement for prisons to accommodate inmates with disabilities, ensuring they have access to necessary medical supplies and services. This case could set a precedent for future claims by inmates who argue that their rights under the ADA have been violated due to a lack of proper accommodations.
Moving forward, the case will return to the lower court for further proceedings. The district court will need to consider whether Adom has standing to seek an injunction that would require the CDCR to provide him with a permanent accommodation order for his incontinence supplies. This ruling opens the door for a reevaluation of how prisons handle disability accommodations, potentially affecting many inmates across the state.
Details were not available in the court filing regarding whether the CDCR plans to appeal this decision or if there are any related cases pending. However, the outcome of this case could influence how similar cases are handled in the future, particularly those involving the rights of disabled individuals within the prison system.