How have courts dealt with postjudgment motions requiring defendants to accommodate the needs of inmates who are housed in county jails?

First, in Armstrong v. Schwarzenegger, 622 F.3d 1058 (9th Cir. 2010), the district court had years earlier required the state defendants to produce a remedial plan to provide disability accommodations for prisoners and had issued a permanent injunction directing enforcement of the plan. Id. at 1063. Plaintiffs brought a postjudgment motion to require defendants to accommodate the needs of class members housed in county jails. Id. The district court determined that defendants were violating their statutory duties and the court's prior orders by failing to provide disability accommodations to class members housed in county jails, and it "ordered defendants to develop and issue to the counties a plan to comply with the [Americans with Disabilities Act] by improving the tracking of state prisoners and parolees they house in county jails," among other things. Id. at 1064.