Summary of University of Alabama v. Garrett
Federal Power to Regulate Private Conduct under the 14th -Interpretive Power
Relevant Facts: Resp Garrett was the Director of Nursing for U. of A she was diagnosed w/ breast cancer, and b/c of her treatment lost time at work. Her supervisor informed her that she would have to step down. She the became a nurse manager. Resp Ash worked as a security officer with A Youth Service Dept. Initially he informed his employer that he suffered from asthma and that dr stated he should avoid carbon monoxide and cigarette smoke. He was later diagnosed with sleep apnea and requested dayshift assignments. All requests were denied.
Legal Issue(s): Whether employees of the State of Alabama may recover money damages by reason of the State’s failure to comply with the ADA requirements?
Court’s Holding: No
Procedure:State Employees brought separate actions under, inter alia, the Americans with Disabilities Act (ADA) against trustees for state university and Alabama Department of Youth Services. Defendants separately moved for summary judgment. The US D Ct , granted both motions on the ground of sovereign immunity. Employees appealed, Ct App reversed; Revered.
Law or Rule(s): In order to authorize private individuals recovery of money damages against a state, there must be a pattern of discrimination by the States which violates the 14th AND the remedy must be congruent and proportional to the targeted violation.
Court Rationale: The Act’s application to the States would allow Congress to rewrite the 14th Amendment law laid down by Cleburne. The first step is to identify the Constitutional right at issue. The limitations of the equal protection of the 14th upon the States’ treatment of the disabled. Previous decisions concluded that under a rational basis, where a group possesses distinguishing characteristics relevant to interests the State has the authority to implement, a State’s decision to act on the basis of those differences does not give rise to a constit violation. Special accommodations requirements for the disabled do not come from the 14th. Second, the history and pattern of the practice involved by the State’s against the disabled. The legislative record only has minimal evidence to support a pattern by the states or local govt. Historically, society has isolated and segregated the disabled, but that is a social problem.
Plaintiff’s Argument: (Res) Unconstitutional discrimination extends to the local units of govt, cities and towns, b/c they are state actors.
Defendant’s Argument: The respondent are barred by the 11th and 14th from recovery of money against the states for failing to adhere the practices of the ADA. This suit is not a valid exercise of Congress’ 14th sec 5 power.
MINORITY – the record is saturated with evidentiary accounts, made to Congress prior to passage of the Act, of invidious and adverse treatment of persons with disabilities. The record indicates that state govt subjected those w/ disabilities to seriously adverse disparate treatment. There is nothing wrong with a remedy that in response to an unreasonable employer’s behavior, requires the employer to make accommodations that are reasonable.
The improperly invalidates a power that the Constitution assigned to Congress. Sec 5 14th .
Cleburne – “States are not required by 14th to make special accommodations for the disabled, so long as their actions toward such individuals are rational."