Mathis v. United States Parole Commission

District Court, District of Columbia·Decided February 11, 2025·No. Civil Action No. 2024-1312·Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

KENNEDY DAVIS, Plaintiff,

v. Case No. 1:24-cv-01312 (TNM)

UNITED STATES PAROLE COMMISSION, et al.,

Defendants.

MEMORANDUM ORDER

Kennedy Davis is on parole. He allegedly faces systemic disability discrimination from the two federal agencies that supervise him. And he insists he is not alone. 1 So he moves for class certification to litigate on behalf of other disabled individuals on parole and supervised release who also suffer from discrimination. Defendants—the U.S. Parole Commission, the Court Services and Offender Supervision Agency, and the heads of those agencies in their official capacities (collectively, “the Government”)—oppose class certification. They say the class does not satisfy some prerequisites: members do not share a common injury, and Davis’s claim is not typical for the class. The Court disagrees. The supervision program allegedly harbors a system-wide flaw that injures the entire class—Davis included—and can be remedied through the same injunctive relief. So the Court will certify Davis’s proposed class and appoint Davis’s lawyers as class counsel.

1 William Mathis was previously a named Plaintiff but passed away in mid-2024. ECF No. 34. Counsel voluntarily dismissed his claim, id., leaving Davis as the sole named Plaintiff.

I.

The Court begins by summarizing the supervision system for offenders in Washington, D.C., who were convicted under D.C. law. Parole and supervised release are both forms of post- incarceration supervision. Parole applies to offenses committed before August 5, 2000, while supervised release applies to any crimes committed after that date. See Sentencing Reform Amendment Act of 2000, D.C. Law 13-302.

Two federal agencies work together to supervise D.C. Code offenders. The U.S. Parole Commission is the lead agency and has major decision-making authority. See National Capital Revitalization and Self-Government Improvement Act of 1997 (“Revitalization Act”), Pub. L. No. 105-33, § 11231, 111 Stat. 712, 745; 28 C.F.R. § 2.70(a) (parole); id. § 2.200(a) (supervised release). It sets general supervision conditions and decides whether an offender’s term of parole or supervised release should be continued, revoked, or terminated. See 28 C.F.R. § 2.70(a)–(b); id. § 2.200(a)–(b).

The Court Services and Offender Supervision Agency (“CSOSA”) implements the Commission’s decisions. Its officers, known as CSOs, provide the day-to-day “supervision . . . for offenders on probation, parole, and supervised release pursuant to the District of Columbia Code.” Revitalization Act § 11233(c)(1) (codified at D.C. Code § 24-133(c)(1)). They ensure offenders comply with their conditions, set the location and frequency of check-ins, and initially assess supervision violations. Compl. ¶ 15, ECF No. 1. CSOs respond to non-compliance with “graduated sanctions.” Id. Those sanctions start with increased supervision requirements. Id. But they can escalate to an Alleged Violation Report—a recommendation that the Commission issue an arrest warrant and begin revocation proceedings. Id.

The Commission and CSOSA also work together to decide when an offender should have his supervision revoked and be reincarcerated. Sometimes revocation and reincarceration are triggered by a new criminal offense. But “technical violations” can trigger discipline too. Technical violations happen when an offender violates a condition of release—like missing an appointment with a CSO, failing to get a job, or skipping a drug test. CSOSA FY2024 Budget Justification, ECF No. 3-12, at 35. Though technical violations are typically not premised on criminal conduct, they can still lead to jailtime. Id.

According to the Complaint, offenders with disabilities are especially susceptible to technical violations. Compl. ¶¶ 25, 28. Physical disabilities can impede mobility, making it difficult for an offender to travel to a mandatory check-in with his CSO. Id. ¶ 26. Chronic health conditions present similar difficulties and might require an offender to balance CSO check-ins with medical appointments or hospitalization. Id. Then there are mental, intellectual, and developmental disabilities that may frustrate an offender’s ability to grasp certain conditions or participate in required programs. Id. ¶ 27. Given these obstacles, Davis alleges that “people with disabilities are more likely to be found in violation of terms of supervision” than their non- disabled counterparts. Id. ¶ 28.

Davis is a 48-year-old man on lifetime parole because of his convictions for Second-

Degree Murder and Possession of a Firearm During a Crime of Violence. Mathis v. U.S. Parole Comm’n, 24-cv-01312, 2024 WL 4056568, at *3 (D.D.C. Sept. 5, 2024). Davis experiences chronic pain stemming from third-degree burns on his bones and ribs—injuries that have required multiple rounds of surgery. K. Davis Decl., ECF No. 40-15, ¶¶ 5–6. Davis also has mental health conditions, including depression, anxiety, and PTSD, for which he has received mental health treatment. Id. ¶¶ 7–9. His last set of parole conditions required him to report to

his CSO as requested, get drug tested in-person twice a week, and report every address change. Id. ¶ 11.

Davis’s disabilities have impeded his ability to succeed on supervision. Id. ¶ 17. His burns limit his mobility, which makes it harder for him to travel to drug tests and CSO check-ins. Id. ¶¶ 18–21. And at times, his medical needs have been pitted against his supervision conditions. For instance, when he was first hospitalized for his burns, he left the hospital against his doctor’s orders so he could check in with his CSO as required. Id. ¶ 5.

Davis’s mental health issues also present an obstacle, as shown by one incident in 2023 where he failed to check-in with his CSO by phone. Id. ¶¶ 34–38. When Davis was placed on supervision, he “did not have [his] own phone.” Id. ¶ 34. So his re-entry advocate at University Legal Services (“ULS,” a community-based organization that assists people with disabilities) gave him one. Id. ¶ 34. But ULS forgot to put minutes on it. Id. When Davis realized the oversight, he “got very anxious and scared” because he knew he had to check in. Id. ¶ 35. So instead of rationally thinking through the situation and contacting his CSO by another means, he kept trying to reach ULS because they were “the people [he] trust[ed].” Id. ¶¶ 35–36.

Davis eventually reached ULS, but by then it was too late. Citing his technical violation of failing to check-in, Davis’s CSO submitted a violation report and pursued revocation. Compl. ¶ 111; K. Davis Decl. ¶ 38. He was arrested in August 2023, which caused him to miss a scheduled surgery for his burns. Compl. ¶¶ 111–13; K. Davis Decl. ¶ 40. And because of his technical violation, the Commission imposed a 12-month reincarceration sentence. Compl. ¶ 114; K. Davis Decl. ¶¶ 42–44.

While serving his sentence, Davis filed this suit. See Compl. ¶ 114. His one-count Complaint alleges a violation of the Rehabilitation Act, 29 U.S.C. § 794. Compl. at 30. He

challenges the Government’s ongoing and system-wide failure to assess “disabilities or make any reasonable accommodations at any point during the course of . . . supervision.” Id. ¶ 152. On top of this, Davis says the Government lacks any foundational system or policy for disability assessment and accommodation. Id. ¶ 149. So even if a disabled offender wants to request accommodation, there is no “formal process” to do so. Id. Davis alleges these failures strip him and the proposed class “of meaningful access to the benefits of supervision due to their disabilities.” Id. ¶ 153.

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