Alexander v. Choate (1985)
- Sam Shepherd
- Sep 19, 2024
- 4 min read
Updated: Oct 27, 2024
By Nicole Tursellino
Overview
Alexander v. Choate, 469 U.S. 287 (1985) was heard by the Supreme Court that addressed whether reducing the number of inpatient hospital days (a shift from 20 to 14 days) covered by Medicaid per year inequitably impacted individuals who possessed disabilities, disabilities that required these individuals to spend more time in the hospital to recover. The Supreme Court unanimously ruled under a majority opinion produced by Justice Thurgood Marshall that reducing the number of days in the hospital covered by Medicaid did not intentionally discriminate against individuals who have disabilities, ultimately clarifying that Section 504 of the Rehabilitation Act of 1984 only serves to protect individuals who have been intentionally discriminated against by a group or organization.
Summary
During the 1980’s, the state of Tennessee was searching for different outlets to help diminish the amount of money that legislators were paying for their state’s Medicaid program. In an effort to help reduce the money being spent, the state decided to reduce its number of inpatient hospital days covered by the Tennessee Medicaid program from 20 in-patient hospital days to 14 in-patient hospital days. With this shift, individuals with disabilities saw that this would have a negative impact on their health and recovery, as individuals with disabilities typically required longer stays once admitted into hospital programs. “The undisputed statistical evidence was that in the year before the proposed limit, 27.4% of all users of hospital services with disabilities who received Medicaid required more than fourteen days of care, while only 7.8% of non-disabled users required more than fourteen days of inpatient care-a three-fold difference” (Francis, Silvers 448).
With this, individuals who had been Tennessee Medicaid recipients challenged Section 504 of the Rehabilitation Act of 1973 in its premise about discrimination against individuals who possessed disabilities in programs funded by the federal government. When presented in the District Court, the Court decided to dismiss the plaintiff’s case, stating that this particular form of discrimination that the plaintiffs were arguing did not fall under Section 504 of the Rehabilitation Act. However, the Court of Appeals found the plaintiffs had established a case of a Section 504 violation.
Upon entering the Supreme Court, the Justices turned to the precedent set by Southeastern Community College v. Davis, 442 U.S. 397 (1979), which stated that a federally funded college program was not required to alter its foundational requirements and adjust the institution's nursing program to suit the needs of a handicapped student who did not possess other qualifications for admittance into the program. With this precedent in mind, the Justices ruled under the majority opinion produced by Justice Thurgood Marshall that the Medicaid Program’s reduction of 20 days to 14 days of in-patient coverage was “neutral on its face, is not alleged to rest on a discriminatory motive, and does not deny the handicapped meaningful access to or exclude them from the particular package of Medicaid services Tennessee has chosen to provide.”
Impact
The ruling upheld in Alexander v. Choate, 469 U.S. 287 (1985) clarifies the language that makes up Section 504 of the Rehabilitation Act and helps the States understand the ways in which they can and cannot make changes to programs that receive funding from the federal government. This case showed that “Section 504 does not require the State to redefine its Medicaid program” and that it does “not require that federal grantees make a broad-based distributive decision always in the way most favorable, or least disadvantageous, to the handicapped.” It shows that if the state makes changes to a federally funded program that intentionally harms the handicapped, then it would be a violation of the law; however, making a change to the law without intentionally doing so would not be.
This case also highlights what “meaningful access” in the court of law is defined as; “such a standard is far from requiring maximal benefit or equality of results, but it is not a negligible ‘any minimal access’ standard either” (Francis, Silvers 453). Choate has also been used as a precedent in cases such as Olmstead v. L.C., 527 U.S. 581 (1999), a case that highlighted mental disabilities and utilized Choate to show intentional vs. unintentional discrimination against individuals with these handicaps. It has also served as a precedent in Winkelman v. Parma City School District, 550 U.S. 516 (2007), which utilized Choate in a situation concerned with parental guardians representing children that have disabilities in disputes with others.
Alexander v. Choate brings to light the ways in which changes to policies are seen as discriminatory, and shows the ways in which the intentions behind certain actions have an impact on the way in which violations of the law are seen by the Supreme Court.
Additional Documents
To listen to the Oral Argument made on October 1, 1984, click here:
To read more about the Opinions and Dissents of the case, click here:
To learn more about Section 504 of the Rehabilitation Act of 1973, click here:
To learn more about Olmstead v. L.C., 527 U.S. 581 (1999), click here:
To learn more about Winkelman v. Parma City School District, 550 U.S. 516 (2007), click here:
To learn more about Southeastern Community College v. Davis, 442 U.S. 397 (1979), click here:
To read more about the Tennessee Medicaid Program, click here:
Citations
Alexander v. Choate, 469 U.S. 287 (1985)
Alexander V. Choate, 469 U.S. 287 (1985) | Findlaw, caselaw.findlaw.com/court/us-supreme-court/469/287.html. Accessed 15 Sep. 2024.
Francis, Leslie Pickering, and Anita Silvers. "Debilitating Alexander v. Choate: 'Meaningful Access' to Health Care for People with Disabilities." Fordham Urban Law Journal, vol. 35, no. 3, 2008, pp. 447-490. Fordham Law School, https://ir.lawnet.fordham.edu/ulj/vol35/iss3/6. Accessed 14 Sep. 2024.
Francis, Leslie, and Anita Silvers. "Reading Alexander V. Choate Rightly: Now Is the Time." Laws, vol. 6, no. 4, 2017, https://doi.org/10.3390/laws6040017. Accessed 14 Sep. 2024.
“Rehabilitation Act of 1973.” 29 U.S.C, Section 794.
