Board of Trustees of the University of Alabama v. Garrett
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| Board of Trustees of the University of Alabama v. Garrett | ||||||||||||||
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 Supreme Court of the United States |
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| Argued October 11, 2000 Decided February 21, 2001 |
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| Holding | ||||||||||||||
| The Court held that Congress's enforcement powers under the Fourteenth Amendment to the Constitution did not extend to the abrogation of state sovereign immunity under the Eleventh Amendment where the discrimination complained of was rationally based on a disability. | ||||||||||||||
| Court membership | ||||||||||||||
| Chief Justice: William Rehnquist Associate Justices: John Paul Stevens, Sandra Day O'Connor, Antonin Scalia, Anthony Kennedy, David Souter, Clarence Thomas, Ruth Bader Ginsburg, Stephen Breyer |
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| Case opinions | ||||||||||||||
| Majority by: Rehnquist Joined by: O'Connor, Scalia, Kennedy, Thomas Concurrence by: Kennedy Joined by: O'Connor Dissent by: Breyer Joined by: Stevens, Souter, Ginsburg |
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| Laws applied | ||||||||||||||
| U.S. Const. amends. XI, XIV | ||||||||||||||
Board of Trustees of the University of Alabama v. Garrett, 531 U.S. 356 (2001),[1] was a United States Supreme Court case that determined that the Congress's enforcement powers under the Fourteenth Amendment to the Constitution did not extend to the abrogation of state sovereign immunity under the Eleventh Amendment where the discrimination complained of was rationally based on disability.
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[edit] Facts
For more information on decisions of the William Rehnquist Court that include the issues of States' Rights and Civil Rights, see Kimel v. Florida Board of Regents and United States v. Morrison
The plaintiffs were Milton Ash and Patricia Garrett, employees of the University of Alabama school system. Both were disabled under the definition of the Americans with Disabilities Act (ADA): Ash had a lifelong history of severe asthma, and Garrett had been diagnosed with breast cancer, and had received radiation and chemotherapy treatments. Both alleged that they had been discriminated against at their jobs, and filed a suit in federal court against the University of Alabama for money damages, arguing that the University had violated Title I of the ADA.
The University of Alabama responded with a motion to dismiss on the grounds that the Eleventh Amendment prohibited the suit. The United States District Court dismissed both cases on this ground, but the Eleventh Circuit reversed, holding that Congress had expressly abrogated the sovereign immunity of the states.
[edit] Issue
Was Congress able to abrogate the immunity of the states under its Fourteenth Amendment power to enforce the Equal Protection Clause?
[edit] Result
William Rehnquist's majority opinion stated that Congress properly made clear its intention to exercise its Equal Protection Clause Fourteenth Amendment rights against state sovereign immunity from lawsuits, but that the ADA law lacked proportionality and congruence City of Boerne v. Flores and failed to prove the discrimination was irrational. Rehnquist argued that the "reasonable accommodation" requirement of the ADA law failed the congruence and proportionality test even though there was a hardship exception to the accommodation requirement.
Rehnquist said that disability discrimination is rational in that hiring non-disabled employees would conserve scarce financial resources by avoiding the need for costly reasonable accommodations. Rehnquist also said that states have rational reasons for violating the part of the ADA law banning policies that have a disparate impact on the disabled.
Rehnquist said that the burden of proof was upon those who alleged that a state action toward the disabled was irrational. As Rehnquist said, "the burden is upon the challenging party."
As Rehnquist explained:
| Thus, the result of Cleburne is that States are not required by the Fourteenth Amendment to make special accommodations for the disabled, so long as their actions towards such individuals are rational. They could quite hard headedly–and perhaps hardheartedly–hold to job-qualification requirements which do not make allowance for the disabled. If special accommodations for the disabled are to be required, they have to come from positive law and not through the Equal Protection Clause. |
[edit] Dissent
The Court split 5-4, with Justice Stephen Breyer filing a dissenting opinion in which he was joined by Justices John Paul Stevens, David Souter, and Ruth Bader Ginsburg. The dissent argued that even though disparate treatment based on disability is subject only to rational basis review, Congress nevertheless had the power to protect the handicapped from distinctions made with no rational basis. As for "congruence and proportionality", Breyer said that City of Cleburne v. Cleburne Living Center, Inc and Katzenbach v. Morgan were precedents that require deference by the Court to legislation passed by Congress to require equal protection of the laws, and that the Court was using an argument for judicial restraint (the rationality test) as an argument for Congressional restraint and judicial activism. Also, Breyer thought the Court should interprete the sovereign immunity of states according to the Fourteenth Amendment's origin as a Civil War amendment created by a Congress that didn't trust equal protection of the laws to states or the post-Dred Scott Supreme Court.
As Breyer said:
| Congress found that “[t]wo-thirds of all disabled Americans between the age of 16 and 64 [were] not working at all,” even though a large majority wanted to, and were able to, work productively. S. Rep. No. 101—116, at 9. And Congress found that this discrimination flowed in significant part from “stereotypic assumptions” as well as purposeful unequal treatment.” ...
The problem with the Court’s approach is that neither the “burden of proof” that favors States nor any other rule of restraint applicable to judges applies to Congress when it exercises its §5 power. “Limitations stemming from the nature of the judicial process … have no application to Congress.” Oregon v. Mitchell [citations omitted] Rational—basis review–with its presumptions favoring constitutionality–is “a paradigm of judicial restraint.” FCC v. Beach Communications, Inc. [citations omitted] And the Congress of the United States is not a lower court. ... I recognize nonetheless that this statute imposes a burden upon States in that it removes their Eleventh Amendment protection from suit, thereby subjecting them to potential monetary liability. Rules for interpreting §5 that would provide States with special protection, however, run counter to the very object of the Fourteenth Amendment. By its terms, that Amendment prohibits States from denying their citizens equal protection of the laws. U.S. Const., Amdt. 14, §1. Hence “principles of federalism that might otherwise be an obstacle to congressional authority are necessarily overridden by the power to enforce the Civil War Amendments ‘by appropriate legislation.’ Those Amendments were specifically designed as an expansion of federal power and an intrusion on state sovereignty.” City of Rome |
[edit] Related Issues
A rational basis review was all that was required in the Garrett decision. The Court's subsequent Alexander v. Sandoval (2001) is an example of a Court decision where strict scrutiny was required.
