Monday, January 6, 2014

Board of Trustees v. Garrett case brief

Board of Trustees v. Garrett case brief summary
531 U.S. 356 (2001)

Appellant's petition for writ of certiorari to the United States Court of Appeals for the Eleventh Circuit was granted in a case involving whether respondent state employees could have recovered money damages for petitioner state agency's failure to comply with Title I of the Americans with Disabilities Act, 42 U.S.C.S. §§ 12111-12117.

The lower court had held that the Americans with Disabilities Act (ADA) validly abrogated the States' immunity under the Eleventh Amendment, U.S. Constitutional Amendment XI.


  • Relying on its prior equal protection precedent, the court concluded that states were not required by U.S. Constitutional Amendment XIV to make special accommodations for the disabled, so long as their actions towards such individuals had a rational basis. 
  • Thus, if special accommodations for the disabled were to be required, they would have had to come from positive law and not through the Equal Protection Clause, U.S. Constitutional Amendment XIV. 
  • Congress had not identified a history and pattern of unconstitutional employment discrimination by the states against the disabled because its general findings and the anecdotal incidents in the ADA's legislative history fell short of suggesting a pattern of unconstitutional discrimination on which U.S. Constitutional Amendment XIV, § 5, legislation was required to be based.
  • Even if a pattern of discrimination were shown, however, the rights and remedies in the ADA were not congruent and proportional to the targeted violation given the ADA's sweeping requirements.

Judgment of the lower court was reversed because Congress had not identified history and pattern of unconstitutional employment discrimination against disabled by states sufficient to abrogate States' Eleventh Amendment immunity.

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