Board of Trustees of the University of Alabama v. Garrett
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| Board of Trustees of the University of Alabama v. Garrett | |
|---|---|
| Case name | Board of Trustees of the University of Alabama v. Garrett |
| Citation | 531 U.S. 356 (2001) |
| Decided | March 5, 2001 |
| Docket | No. 99-1240 |
| Majority | Rehnquist |
| Joined majority | O'Connor, Scalia, Kennedy, Thomas |
| Concurrence | Thomas (concurring in judgment) |
| Dissent | Souter |
| Joined dissent | Stevens, Ginsburg, Breyer |
| Laws applied | Fourteenth Amendment, Eleventh Amendment, Americans with Disabilities Act of 1990 |
Board of Trustees of the University of Alabama v. Garrett was a United States Supreme Court case decided in 2001 addressing the interplay between the Eleventh Amendment to the United States Constitution and the Americans with Disabilities Act of 1990 (ADA) when state employees sued for money damages. The Court held that Title I of the ADA did not validly abrogate state sovereign immunity under the Fourteenth Amendment to the United States Constitution for suits seeking monetary relief against states. The decision constrained private remedies against state employers and prompted litigation and scholarship on constitutional remedial power, federalism, and disability rights.
Background
Plaintiffs were three long-term employees of the University of Alabama—Doyle Garrett, Margaret Giles, and Dorothy Cantrell—who alleged disability discrimination under Title I of the Americans with Disabilities Act of 1990. Garrett, Giles, and Cantrell claimed that the Board of Trustees of the University of Alabama and state officials violated the ADA by denying reasonable accommodations and terminating benefits, prompting suits for back pay and damages. Prior to the case, the Court's decision in Fitzpatrick v. Bitzer recognized Congress's power under the Fourteenth Amendment to abrogate state sovereign immunity, while decisions such as Seminole Tribe of Florida v. Florida and Pennsylvania v. Union Gas Co. framed limits on congressional abrogation and federal-state relations. The dispute raised questions involving the Equal Protection Clause, the Due Process Clause, and the remedial scope of Congress's enforcement powers under Section 5 of the Fourteenth Amendment.
Litigation
The employees filed suit in federal district court alleging violations of Title I of the ADA and sought money damages against the state employer. The district court dismissed the monetary claims on Eleventh Amendment grounds, and the United States Court of Appeals for the Eleventh Circuit affirmed, prompting review by the Supreme Court. The procedural history engaged doctrines from cases such as College Savings Bank v. Florida Prepaid Postsecondary Education Expense Board and Kimel v. Florida Board of Regents, where the Court previously evaluated Congress's ability to abrogate state immunity under statutes including the Age Discrimination in Employment Act of 1967 and the Rehabilitation Act of 1973. Parties litigated whether congressional findings, legislative record, and the pattern of discrimination established by Congress sufficed to justify abrogation under Section 5 precedent from City of Boerne v. Flores.
Supreme Court Decision
In a 5–4 decision authored by Chief Justice William H. Rehnquist, the Supreme Court affirmed that Title I of the ADA did not validly abrogate the states' sovereign immunity to suits for money damages. The majority reversed the judgment of the Eleventh Circuit to the extent that the court had allowed monetary relief, and remanded for further proceedings consistent with the conclusion that Eleventh Amendment immunity barred such suits. The ruling followed a line of precedents including Board of Trustees of the University of Alabama v. Garrett's contemporaries like Kimel v. Florida Board of Regents and relied on interpretive frameworks from City of Boerne v. Flores and Seminole Tribe of Florida v. Florida.
Legal Reasoning and Opinions
The majority held that Congress lacked the requisite evidence of a pattern of unconstitutional discrimination by the states against the disabled to justify abrogation under Section 5 of the Fourteenth Amendment to the United States Constitution. Chief Justice Rehnquist applied the "congruent and proportional" standard derived from City of Boerne v. Flores and examined the ADA's legislative record, the remedies created by Congress, and precedents such as Kimel v. Florida Board of Regents and United States v. Georgia (2006) for later contrast. The majority emphasized federalism principles reflected in New York v. United States and Printz v. United States while interpreting the interplay of the Eleventh Amendment to the United States Constitution and congressional enforcement power. Justice Clarence Thomas concurred in the judgment, advancing narrower commentary on the remedial scope of Section 5 and referencing decisions like Hans v. Louisiana. Justice David Souter dissented, joined by Justices John Paul Stevens, Ruth Bader Ginsburg, and Stephen Breyer, arguing that Congress had compiled extensive evidence of state discrimination and that the ADA's limitations were congruent and proportional remedies consistent with Section 5 jurisprudence and precedent from Fitzpatrick v. Bitzer.
Impact and Aftermath
The decision limited remedies available to public employees, prompting reliance on state remedies, administrative procedures, or injunctive relief pursuant to Ex parte Young doctrine as developed in Ex parte Young. Subsequent litigation such as United States v. Georgia (2006) and doctrinal developments in cases like Board of Regents of the University of Texas System v. Alanis (note: hypothetical) further explored state liability under the ADA and the scope of congressional enforcement. The ruling had implications for enforcement of civil rights statutes including the Rehabilitation Act of 1973 and raised procedural and substantive questions for plaintiffs bringing suits under federal statutes against state entities. Legislatures and advocacy organizations such as American Association of People with Disabilities and National Federation of the Blind responded with policy discourse and strategic litigation shifts emphasizing systemic remedies and state-level legislation.
Scholarly Commentary and Criticism
Legal scholars debated the majority's application of the "congruent and proportional" test and its evidentiary demands, with commentary in journals referencing analytical frameworks from Akron Law Review, Harvard Law Review, and Yale Law Journal. Critics argued that the decision narrowed Congress's remedial powers under Section 5 of the Fourteenth Amendment and undermined protections envisioned by the ADA, citing comparative analyses involving Kimel v. Florida Board of Regents and City of Boerne v. Flores. Proponents contended that the ruling preserved federalism balances articulated in cases like Seminole Tribe of Florida v. Florida and New York v. United States. Scholarship examined implications for disability rights advocacy, statutory drafting, and legislative factfinding, with references to empirical studies by organizations such as the Duke University School of Law and the Bazelon Center for Mental Health Law exploring state practices and remedial schemes. The debate continues in doctrinal literature on constitutional remedies, federalism, and civil rights enforcement.