School Board of Nassau County v. Arline

School Board of Nassau County v. Arline
Litigants	School Board of Nassau County v. Arline
Argued	October 30, 1986
Decided	March 3, 1987
Full name	School Board of Nassau County v. Arline
Us vol	480
Us page	273
Parallel citations	107 S. Ct. 1128; 94 L. Ed. 2d 307; 1987 U.S. LEXIS 1016
Holding	A contagious disease that is substantially limiting qualifies as a "handicap" under the Rehabilitation Act of 1973
Majority	Stevens
Joinmajority	Brennan, Marshall, Blackmun, O'Connor, Scalia, Kennedy
Dissent	White
Laws applied	Rehabilitation Act of 1973

School Board of Nassau County v. Arline was a 1987 decision of the Supreme Court of the United States interpreting the scope of "handicap" under the Rehabilitation Act of 1973. The Court held that a communicable disease that substantially limits major life activities can qualify for statutory protection, directing the United States Court of Appeals for the Second Circuit and lower tribunals on remedial standards. The ruling influenced later interpretations in cases before the United States Court of Appeals for the Ninth Circuit, United States Court of Appeals for the D.C. Circuit, and informed jurisprudence culminating in Americans with Disabilities Act of 1990 litigation.

Background

The case arose amid debates over the application of the Rehabilitation Act of 1973 to employees with chronic illnesses. Litigants invoked statutory provisions administered by the United States Department of Health, Education, and Welfare and later by the Equal Employment Opportunity Commission. Precedent from the Supreme Court of the United States such as Henderson v. United States and administrative interpretations from the Office of Personnel Management framed the agency deference questions. The matter reached the federal circuit courts following employment actions and appeals involving the School Board of Nassau County, Florida and state administrative procedures in Florida.

Case Facts

Respondent Arline, a long-term employee, was diagnosed with a communicable, chronic condition that presented intermittent infectivity concerns and required workplace accommodation. The School Board of Nassau County placed employment restrictions and raised concerns citing health risks to students and staff. Arline filed administrative complaints and then sued under section 504 of the Rehabilitation Act of 1973, alleging discrimination and seeking reinstatement and damages. The United States Court of Appeals for the Eleventh Circuit and district courts addressed whether her condition met the statutory definition of "handicap" and whether reasonable accommodation was required.

Legal Issues

The primary legal questions were (1) whether a contagious disease that is not outwardly visible constitutes a "handicap" under section 504 of the Rehabilitation Act of 1973; (2) whether risk of contagion justified adverse employment action under federal anti-discrimination protections; and (3) to what extent courts must defer to agency interpretations, implicating doctrines from Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. and precedent on statutory construction from the Supreme Court of the United States.

Supreme Court Decision

In an opinion delivered by Justice John Paul Stevens, the Supreme Court of the United States reversed the judgment below and held that a communicable disease that substantially limits a major life activity fits within the statutory term "handicap." The Court resolved the appeal by emphasizing statutory text, legislative history, and administrative interpretations, applying principles articulated in earlier decisions such as Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. and relying on agency guidance from the Equal Employment Opportunity Commission. Justice Clarence Thomas did not participate; Justice Byron White dissented in part.

Reasoning and Precedent

The majority reasoned that the ordinary meaning of "handicap" encompassed both physical and mental impairments, and that the presence of communicability did not exclude coverage if the impairment substantially limited major life activities. The opinion surveyed legislative history of the Rehabilitation Act of 1973 and cited administrative materials from the Department of Health and Human Services and the Equal Employment Opportunity Commission. The Court applied principles from Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. regarding deference to reasonable agency interpretations and distinguished prior holdings from the Supreme Court of the United States on statutory ambiguity. The decision engaged with constitutional avoidance doctrines reflected in cases like Regan v. Time, Inc. and statutory interpretation in Brown v. Board of Education jurisprudence as illustrative of remedial purposes.

Impact and Significance

The ruling extended protections under the Rehabilitation Act of 1973 to a wider class of conditions and influenced subsequent cases under the Americans with Disabilities Act of 1990, including litigation in the United States Court of Appeals for the Second Circuit and United States Court of Appeals for the Fourth Circuit. Administrative agencies revised guidance and enforcement priorities, affecting employment practices in school systems such as those in Florida, New York, and California. Scholars in law schools at Harvard University, Yale University, and Columbia University have treated the decision as pivotal in disability law curricula alongside landmark opinions like Olmstead v. L.C. and Sutton v. United Airlines, Inc.. The case remains cited in modern disputes involving workplace accommodation, public health, and the interplay between statutory text and administrative interpretation.

Category:United States Supreme Court cases Category:1987 in United States case law Category:Disability law in the United States