Mass. Appeals Court hears argument over ADA accommodation for unusually tall inmate

The Massachusetts Appeals Court heard argument March 18, 2025, in 24 P.H. 23, Joshua Carrier v. James Ryu and James O’Gara, over whether the Commonwealth’s Department of Correction (DOC) must treat Carrier’s height-related needs as an ADA-covered disability. Carrier, appearing pro se, said his 6-foot-7 stature prevents him from using a standard cell mattress and from sitting comfortably at a fixed desk and chair in his cell; the DOC’s attorney said the record does not show a disability that substantially limits a major life activity and that the department has already ordered a longer mattress.

The matter matters because an appellate ruling that height-based restrictions qualify as ADA disabilities could broaden the set of conditions courts treat as disabilities in correctional settings and affect how DOCs nationwide handle housing and equipment accommodations. Justice Greg Massing, sitting with Justices Eric Nyman and Chauncey Wood, heard about Carrier’s long-standing requests for a longer mattress and for minor modifications to the fixed desk-and-chair unit in his cell.

Carrier told the court that for about 10 years the DOC had provided a longer mattress for him, that after a department-wide mattress replacement the longer mattress was removed, and that he has waited months for a replacement. He said the lack of an appropriately sized mattress interferes with sleep and that the…