How have the courts dealt with claims of failure to accommodate for a disabled inmate?

personnel requested that he be accommodated by being housed on a lower tier (and a lower bunk). He alleges that this need for accommodation, and the recommendation for accommodation were ignored, and that he was housed on an upper tier. Plaintiff alleges that by reason of this placement, he fell while climbing the steps to his upper tier cell, and was injured. This is enough to state a claim for failure to accommodate under Title II. See Pierce v. County of Orange, 526 F.3d 1190, 1224 (9th Cir.) (prisoner stated a Title II claim for failure to accommodate when he alleged that "he was denied an adequate supply of catheters, and as a result suffered recurrent bladder infections," and that "he was not provided a proper mattress given his disability, and as a result developed bed sores"), cert. denied, 555 U.S. 1031 (2008).

The court will deny the County's motion to dismiss Claim 5.