Tyrone White v. Kilolo Kijakazi

I. Background

White was born in 1971. On October 9, 2009, he was shot three times in what he described as a “random shooting.” Fragments from one of the bullets remain lodged in White’s S1 vertebra, projecting into his spinal canal. Due to the presence of the bullet fragment, White’s left leg has atrophied; he experiences significant chronic pain; and he has difficulty sitting for more than 10–15 minutes at a time or walking more than 50–60 yards. He walks with the aid of a cane. He lives with his mother, who does the household chores, including cooking, cleaning, laundry, and yard work.

In January 2010, White was awarded SSI disability benefits. His benefits were later discontinued when he was incarcerated in California. White’s prison medical records document his continuing pain and his difficulty in walking and standing. The prisons in which White was incarcerated accommodated his disability by granting him lower-bunk and lower-tier status, an extra mattress, and use of a cane. White was assigned jobs that accommodated his disability but allowed him to earn sentence credits—wiping off the dining room tables and dusting off the top of lockers in his dorm. He worked in the…