Caroline E. Jackson

Caroline Jackson is senior counsel at Rosen Bien Galvan & Grunfeld LLP. She works on complex litigation and pre-litigation matters, including class actions, with a particular focus on the rights of people with disabilities. Ms. Jackson has significant experience, both at the trial and appellate levels, pursuing ADA and Rehabilitation Act claims on behalf of deaf and hard of hearing individuals.

Ms. Jackson is a graduate of Stanford Law School, and holds a Master’s degree in Education Policy from the Stanford Graduate School of Education, a Bachelor’s degree magna cum laude from Harvard University, and an Associate’s degree in sign language interpreting from Sinclair Community College. Ms. Jackson clerked for the Hon. R. Guy Cole, Jr., former Chief Judge of the U.S. Court of Appeals for the Sixth Circuit. Thereafter, she was awarded the Skadden Fellowship to work at the National Association of the Deaf (NAD) where she remained as a litigator until joining RBGG. While at NAD, she also co-taught the Civil Rights of Persons with Disabilities clinic at the University of Maryland Carey School of Law. In addition, Ms. Jackson is fluent in American Sign Language and obtained the National Interpreter Certification in 2007.

At NAD, Ms. Jackson focused on complex civil litigation to enforce federal civil rights laws on behalf of deaf and hard of hearing people. Her work involved suing everything from courts and medical schools to hospitals and jails. She also worked closely with the U.S. Attorneys’ office on multiple cases, securing comprehensive policy changes in hospitals and jails.

 REPRESENTATIVE CASES

• Armstrong v. Newsom: RBGG proved in federal court that California’s prison and parole systems violate the Americans with Disabilities Act and the Rehabilitation Act of 1973 by discriminating against prisoners and parolees with mobility, sight, hearing, learning, mental and kidney disabilities. We secured systemwide injunctive relief to end the discrimination, which was upheld on appeal.  See Armstrong v. Wilson, 942 F. Supp. 1252 (N.D. Cal. 1996), aff’d 124 F.3d 1019 (9th Cir. 1997). We also established that the State is responsible for taking steps to ensure the rights of prisoners and parolees with disabilities are accommodated when it chooses to house them in third-party county jail facilities. See Armstrong v. Brown, 857 F. Supp. 2d 919 (N.D. Cal. 2012), aff’d 732 F.3d 955 (9th Cir. 2013), cert denied, 134 S. Ct. 2725 (2014); and 622 F.3d 1058 (9th Cir. 2010).   The Armstrong litigation has resulted in a series of ground-breaking precedents, including rulings that the ADA does not permit state government agencies to avoid compliance by delegating responsibilities to local governments, and that prisoners cannot be held in solitary confinement solely on account of disability. We are currently working to stop staff misconduct targeting people with disabilities at CDCR.  On September 8, 2020 and March 11, 2021 respectively, Judge Claudia Wilken granted in part our February 2020 and June 2020 motions to stop staff misconduct at six prisons in CDCR.  The Court found that the systemic abuses against incarcerated people with disabilities at—R.J. Donovan Correctional Facility (San Diego, CA)), CSP – Los Angeles County (Lancaster, CA), CSP -Corcoran (Corcoran, CA), Kern Valley State Prison (Delano, CA), Substance Abuse Treatment Facility (Corcoran, CA), and California Institution for Women (Corona, CA) —violate the ADA and prior court orders.  As a remedy, the Court required Defendants to develop plans to install security cameras and use body worn-cameras (BWCs) throughout the six prisons, reform the staff investigation and disciplinary process, and increase supervisory staffing on all yards at the six prisons.  Currently, BWCs and fixed security cameras are in use at all six prisons.  The Court also appointed an expert to oversee implementation of the mandated reforms.  Armstrong v. Newsom, 484 F.Supp.3d 808 (N.D. Cal. 2020); Armstrong v. Newsom, 2021 WL 933106 (N.D. Cal. 2021).  On February 2, 2023, the Ninth Circuit affirmed the September 8, 2020 RJD Order in full and the majority of the March 11, 2021 Five Prisons Order (except provisions regarding increased supervisory staffing and pepper-spray policies, which were vacated.)  Armstrong v. Newsom, 58 F.4th 1283 (9th Cir. 2023).  Relatedly, on July 30, 2020, the Court ordered that CDCR transfer  two witnesses from the prison where they had faced assault, threats and other retaliation for their participation in the litigation.  Armstrong v. Newsom, 475 F. Supp. 3d 1038 (N.D. Cal. 2020). 
• Hernandez v. County of Monterey: We sued the County of Monterey and its private medical provider, California Forensic Medical Group, challenging dangerous and unconstitutional conditions in the County’s Jail, a system plagued by severe overcrowding, outdated facilities, and chronic understaffing.  In 2014, we defeated the defendants’ motions to dismiss and obtained a unique ruling holding that our clients could assert ADA Title III claims against the Jail’s private medical provider.  See Hernandez v. County of Monterey, 70 F.Supp.3d 963 (N.D. Cal. 2014).  The federal court subsequently certified a class of the approximately 950 prisoners in the Jail, along with a sub-class of prisoners with disabilities.  See Hernandez v. County of Monterey, 305 F.R.D. 132 (N.D. Cal. 2015).  On April 14, 2015, the court granted a sweeping preliminary injunction on behalf of the class and sub-class, finding rampant violations of the Constitution and federal law.  See Hernandez v. County of Monterey, 110 F. Supp. 3d 929 (N.D. Cal. 2015). The court approved the parties’ settlement on August 18, 2015, which requires defendants to comply with the requirements of the preliminary injunction and to develop and implement a comprehensive set of plans to enhance services at the Jail.  In November 2015, the Court approved a $4.8 million dollar award of fees and costs to counsel for the plaintiff class.
• Chavez v. County of Los Angeles:  RBGG obtained a favorable settlement of a federal court lawsuit filed on behalf of a woman who is deaf and communicates primarily through sign language.  Ms. Chavez was denied sign language interpreter services during a three-day hospitalization at a Los Angeles public hospital.   Despite her repeated requests, she was never provided an interpreter at any point during her hospitalization, which culminated in the surgical removal of her gallbladder, and she was discharged from the hospital without understanding instructions for post-surgical follow-up care.  Ms. Chavez returned to the hospital twice more thereafter and was again denied interpreter services.  RBGG secured $250,000 in damages on behalf of Ms. Chavez, as well as extensive training of hospital staff and changes to policy to ensure future deaf patients receive interpreting services.