Hoby Buchanan Lawsuit, What It Reveals About Disability Rights in Detention
The Hoby Buchanan lawsuit—formally known as Buchanan v. Harris County—centers on disability rights violations at Harris County Jail in Texas. John “Hoby” Buchanan, a below-the-knee amputee with limited arm function, sued after jail officials moved him from an accessible cell to general population housing that didn’t accommodate his disabilities.
The MacArthur Justice Center secured an important victory in the Fifth Circuit. The court held that the sores that Mr. Buchanan developed on his residual limb satisfy the Prison Litigation Reform Act’s “physical injury” requirement.
This ruling matters for anyone with disabilities in detention facilities nationwide.
How the Law Works
Americans with Disabilities Act in Jails
The ADA requires correctional facilities to provide reasonable accommodations for inmates with disabilities. Buchanan claimed his rights under the US Constitution and Americans With Disabilities Act (ADA) had been violated when he was placed in inaccessible cells.
Jails must modify policies, practices, and physical environments to ensure disabled inmates can safely perform basic daily tasks like bathing, using the toilet, and accessing their bunks.
Prison Litigation Reform Act Requirements
The PLRA imposes barriers to prisoner lawsuits, including a “physical injury” requirement for certain claims. The lawsuit was dismissed in part because the court believed that he failed to adequately allege a “physical injury,” a requirement imposed by the Prison Litigation Reform Act on some prisoner lawsuits.
Some courts had interpreted this to require injuries that were “more than de minimis”—meaning more than minimal or trivial. The Fifth Circuit’s ruling in Buchanan’s case rejected this overly strict interpretation.
Constitutional Protections Against Cruel and Unusual Punishment
The Eighth Amendment prohibits cruel and unusual punishment, which includes deliberate indifference to serious medical needs and unsafe conditions. When jail officials know about a disability but fail to provide necessary accommodations, they may violate constitutional protections.
The Buchanan case demonstrates how disability-related harm intersects with constitutional rights in detention settings.
Common Scenarios
Physical Accessibility Failures
Inmates with mobility limitations frequently face inaccessible cells without grab bars, accessible showers, or lower bunks. For four months, housed in inaccessible cells, Buchanan struggled to safely bathe, use the toilet, get in and out of his bunk, and simply manage the daily self-care tasks that even people in jails and prisons typically take for granted.
These conditions create daily safety risks and injuries.
Abrupt Transfers Without Medical Justification
Correctional facilities sometimes move disabled inmates from accessible housing to general population without evaluation or explanation. After ten months of pre-trial incarceration in Harris County Jail, guards abruptly punished Mr. Buchanan by moving him out of his handicapped-accessible cell and into one that made life intolerably difficult.
Such transfers can constitute disability discrimination when made without legitimate penological reasons.
Developing Injuries from Lack of Accommodations
When disabled inmates lack proper accommodations, preventable injuries often result. The Buchanan case involved sores developing on his residual limb—injuries the Fifth Circuit found sufficient to meet PLRA’s physical injury threshold.
These injuries demonstrate the concrete harm caused by accessibility failures.
What People Get Wrong
Thinking Disability Rights Don’t Apply in Jails
Many assume jails don’t have to accommodate disabilities the same way public facilities do. Wrong. The ADA and constitutional protections extend to correctional settings.
Incarceration doesn’t eliminate fundamental rights to safe, accessible housing and basic dignity.
Believing Minor Injuries Don’t Count
Some circuits have read the PLRA to demand a physical injury that is “more than de minimis”—a requirement that is inconsistent with the text of the statute. The Fifth Circuit’s ruling clarified that sores, pressure wounds, and similar injuries from lack of accommodations satisfy the physical injury requirement.
You don’t need broken bones or disfigurement to have a valid claim.
What to Do If This Applies to You
Document Everything Immediately
If you or a loved one with disabilities faces accessibility problems in detention, document specific incidents: dates, times, injuries sustained, requests for accommodations made, and officials who denied them.
Photographic evidence of injuries and inaccessible conditions strengthens legal claims.
Exhaust Administrative Remedies
The PLRA requires prisoners to exhaust available administrative remedies before filing lawsuits. File grievances through the facility’s complaint process and keep copies of all filings and responses.
Failure to follow this procedure can result in dismissal of your lawsuit.
Contact Disability Rights Organizations
Organizations like the MacArthur Justice Center, ACLU’s National Prison Project, and state protection and advocacy agencies provide legal assistance for disability rights violations in detention.
These organizations have expertise in navigating PLRA requirements and ADA claims.
FAQs
What was the main issue in the Hoby Buchanan lawsuit?
The lawsuit alleged Harris County Jail violated Buchanan’s ADA and constitutional rights by moving him from accessible housing to inaccessible cells despite his below-the-knee amputation and arm disabilities. The Fifth Circuit ruled his resulting sores constituted sufficient “physical injury” under the PLRA to proceed with his claims.
Does the ADA apply to people in jail?
Yes. The ADA prohibits discrimination against individuals with disabilities in all public entities, including jails and prisons. Correctional facilities must provide reasonable accommodations unless doing so would fundamentally alter the nature of the service or create undue hardship.
What injuries count under the Prison Litigation Reform Act?
The Fifth Circuit in Buchanan’s case clarified that sores, pressure wounds, and similar injuries from lack of disability accommodations satisfy the PLRA’s physical injury requirement. Courts cannot dismiss claims simply because injuries aren’t severe or disfiguring.
Can jails move disabled inmates to inaccessible cells?
Only when there’s legitimate justification and alternative accommodations are provided. Moving disabled inmates to inaccessible housing without medical evaluation or penological reason may violate the ADA and Eighth Amendment protections against cruel and unusual punishment.
How do I file a disability discrimination claim against a jail?
First, exhaust all administrative remedies by filing grievances through the facility’s complaint process. Document all accessibility problems and injuries. Then consult with disability rights organizations or attorneys experienced in prisoner civil rights litigation to evaluate your claim.
What did the Fifth Circuit decide in Buchanan v. Harris County?
The Fifth Circuit held that Buchanan’s sores from lack of accessibility met the PLRA’s physical injury requirement and that he could proceed with his lawsuit. This ruling rejected overly strict interpretations requiring “more than de minimis” injuries before prisoners can seek relief.
Disclaimer
This article about disability rights in detention and the Hoby Buchanan lawsuit provides general legal information for educational purposes only. It does not constitute legal advice, and AllAboutLawyer.com does not provide legal representation or prisoner advocacy services. Disability accommodations, PLRA requirements, and constitutional protections vary based on specific facts and jurisdiction. For guidance on disability rights claims in correctional settings, contact disability rights organizations or consult an attorney experienced in civil rights litigation.
For official information on ADA requirements in correctional facilities, visit the Department of Justice’s ADA resources at https://www.ada.gov.
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This article provides general information only and is not legal advice. Consult a qualified attorney for your specific situation.
Last Updated: January 28, 2026 — We keep this current with the latest legal developments
About the Author
Sarah Klein, JD, is a licensed attorney and legal content strategist with over 12 years of experience across civil, criminal, family, and regulatory law. At All About Lawyer, she covers a wide range of legal topics — from high-profile lawsuits and courtroom stories to state traffic laws and everyday legal questions — all with a focus on accuracy, clarity, and public understanding.
Her writing blends real legal insight with plain-English explanations, helping readers stay informed and legally aware.
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