John Walker v. Donald N. Snyder Jr., Director, Illinois Department of Corrections
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
All 36 flagged citations have been read; the three confirmed treatments are listed below. Later courts continue to apply Walker's separate rule against personal liability under Title II.
36 later cases cite John Walker v. Donald N. Snyder Jr., Director, Illinois Department of Corrections; 36 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on John Walker v. Donald N. Snyder Jr., Director, Illinois Department of Corrections?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Overruled in part
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The Seventh Circuit held that Walker's bar on Title II suits for prospective relief against state officials did not survive Garrett, and restored the plaintiffs' ADA claim.
Bruggeman v. Blagojevich · Seventh Circuit · filed
It is true that Walker v. Snyder, cited earlier, held that only the state, and not state officials, may be sued for violating Title II of the ADA. But that holding, uniformly rejected by the other courts to have considered the issue, ... did not survive Board of Trustees v. Garrett
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Declined to follow
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The Fifth Circuit rejected Walker's bar on Title II suits for prospective relief against state officials and allowed the official capacity suit to proceed.
McCarthy ex rel. Travis v. Hawkins · Fifth Circuit · filed
The State relies primarily on the Seventh Circuit’s opinion in Walker v. Snyder, 213 F.3d 344 (7th Cir.2000).6 In Walker, the court held that a plaintiff could not bring an Ex parte Young suit to enforce Title II because the only proper defendant “is the public body as an entity.” Id. at 347. ... We thus join the Second, Sixth, Seventh, Eighth, and Ninth Circuits in holding that Plaintiffs’ Ex parte Young suit to enforce Title II can proceed;
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Questioned
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The district court questioned whether Walker's sovereign immunity analysis survived Lane for Title II claims outside access to courts; it did not decide the immunity issue.
Brettler v. Purdue University · N.D. Ind. · filed
Although Walker is no longer good law after Lane insofar as it applies to individual claims for money damages against the States under Title II for claims relating to access to courts, the narrow holding of Lane leaves in question the validity of Walker as to other claims brought under Title II of the ADA.
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