McBride v. Michigan Department of Corrections

The Michigan Department of Corrections (DOC) (defendant) received federal funds. The DOC provided its deaf and hard-of-hearing prisoners (collectively, the deaf prisoners) (plaintiffs) with teletypewriters (TTYs) for telephonic communications with outsiders but few other communication aids. The deaf prisoners had no video-communication options and often lacked qualified translators, even for high-stakes interactions like receiving medical care. The deaf prisoners sued the DOC in federal district court, alleging that the DOC had violated federal law by not providing them with communication options as effective as those for other prisoners. Both parties moved for summary judgment. The DOC contended that TTYs were sufficient because they gave deaf prisoners meaningful access to outside communications and that the DOC could not effectively monitor real-time video communications due to safety concerns. The DOC also claimed it was providing sufficiently effective services, such as medical care, because the deaf prisoners’ medical outcomes had been acceptable. Lastly, the DOC asserted it had no legal obligation to provide communication options for voluntary prison programs or programs led by volunteers. In response, the deaf prisoners presented expert evidence that few people still used TTYs and that video communication was the only current option as effective as the audio calls available to other prisoners. The deaf prisoners also showed that the DOC did not monitor audio calls in real time but reviewed transcripts afterward and could do the same for video calls. A magistrate judge considered the summary-judgment motions.