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Board of Trustees of the University of Alabama v. Garrett
Supreme Court of the United States
Argued October 11, 2000 Decided February 21, 2001
Full case name: Board of Trustees of the University of Alabama, et al. v. Patricia Garrett, et al. Citations: 531 U.S. 356; 121 S. Ct. 955; 148 L. Ed. 2d 866; 2001 U.S. LEXIS 1700; 69 U.S.L.W. 4105; 11 Am. Disabilities Cas. (BNA) 737; 2001 Cal. Daily Op. Service 1471; 2001 Daily Journal DAR 1857; 2001 Colo. J. C.A.R. 968; 14 Fla. L. Weekly Fed. S 92 Prior history: 193 F.3d 1214 (11th Cir. 1999). On writ of certiorari to the United States Court of Appeals for the Eleventh Circuit Subsequent history: 261 F.3d 1242 (11th Cir. 2001), vacated on rehearing, 276 F.3d 1227 (11th Cir. 2001), on remand, 223 F. Supp. 2d 1244 (N.D. Ala. 2002), vacated and remanded, 344 F.3d 1288 (11th Cir. 2003), on remand, 354 F. Supp. 2d 1244 (N.D. Ala. 2005)
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
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
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 about Congress's enforcement powers under the Fourteenth Amendment to the Constitution. It decided that the Americans with Disabilities Act was unconstitutional insofar as it allowed states to be sued for money damages.

Contents 1 Facts 2 Issue 3 Result 4 Dissent 5 References

[edit] Facts

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

The majority opinion stated that Congress, in enacting the ADA, had made clear its intention to exercise its power under the Fourteenth Amendment to abrogate state sovereign immunity and allow states to be sued for damages.

It also held, however, that the ADA lacked the "congruence and proportionality" required by City of Boerne v. Flores. Under the Equal Protection Clause, discrimination against people with disabilities is analyzed using "rational basis" scrutiny. If the discrimination has a rational basis, it is constitutional.

The holding of Garrett said 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.^[2]

The Court 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,^[3] and that states have rational reasons for violating the part of the ADA law banning policies that have a disparate impact on the disabled.^[4]

Rehnquist's opinion for the Court 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."^[5]

As the Court 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.

”

The ADA, by allowing states to be sued for damages for failing to provide reasonable accommodations, thus provided significantly more protection than was allowed by Boerne. This level of protection, the Court held, was not "congruent and proportional" to the wrong which could constitutionally be remedied – namely, irrational discrimination against people with disabilities. Hence the law did not constitutionally abrogate the states' sovereign immunity.

[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.

The dissent stated:

“

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] References

1. ^ 531 U.S. 356 (Full text of the decision courtesy of Findlaw.com)
2. ^ The ADA does except employers from the “reasonable accommodatio[n]” requirement where the employer “can demonstrate that the accommodation would impose an undue hardship on the operation of the business of such covered entity.” §12112(b)(5)(A). However, even with this exception, the accommodation duty far exceeds what is constitutionally required in that it makes unlawful a range of alternate responses that would be reasonable but would fall short of imposing an “undue burden” upon the employer. The Act also makes it the employer’s duty to prove that it would suffer such a burden, instead of requiring (as the Constitution does) that the complaining party negate reasonable bases for the employer’s decision. See ibid. - Opinion of the Court
3. ^ whereas it would be entirely rational (and therefore constitutional) for a state employer to conserve scarce financial resources by hiring employees who are able to use existing facilities, the ADA requires employers to “mak[e] existing facilities used by employees readily accessible to and usable by individuals with disabilities. - Opinion of the Court
4. ^ The ADA also forbids "utilizing standards, criteria, or methods of administration" that disparately impact the disabled, without regard to whether such conduct has a rational basis. §12112(b)(3)(A). Although disparate impact may be relevant evidence of racial discrimination, see Washington v. Davis, 426 U. S. 229, 239 (1976), such evidence alone is insufficient even where the Fourteenth Amendment subjects state action to strict scrutiny. - Opinion of the Court
5. ^ Moreover, the State need not articulate its reasoning at the moment a particular decision is made. Rather, the burden is upon the challenging party to negative “ ‘any reasonably conceivable state of facts that could provide a rational basis for the classification.’ ” Heller, supra, at 320 (quoting FCC v. Beach Communications, Inc., 508 U.S. 307, 313 (1993)). - Opinion of the Court