Board of Trustees of University of Alabama v. Garrett (2001)
- Sam Shepherd
- Feb 10
- 5 min read
By Andrew Dawson
Overview
In Board of Trustees of University of Alabama v. Garrett (2001), the U.S. Supreme Court ruled that Title I of the Americans with Disabilities Act (ADA) was unconstitutional because it allowed states to be sued by private citizens for monetary damages. This ruling was a significant blow to congressional power because “the Supreme Court held that Congress had not validly abrogated the states' sovereign immunity because Title I of the ADA exceeded Congress's powers under Section 5 of the Fourteenth Amendment.” The Supreme Court ruling found that Congress did not identify a pattern of discrimination against the disabled by the states and that the remedies offered by Title I of the ADA went too far because they “prohibited too much conduct that was constitutionally permissible” (Legal Momentum).
Summary
Milton Ash and Patricia Garrett (the plaintiffs) were both employees of the University of Alabama and qualified as disabled under the ADA. Specifically, Ash was a security officer and had a history of asthma. He requested that the University of Alabama modify his duties to accommodate this disability. However, none of Ash’s relief requests were granted and thus his job performance declined. Garrett was the Director of Nursing for the University of Alabama in Birmingham and diagnosed with breast cancer, which required her to take a substantial amount of leave from work. However, when she returned to work, she was informed that she would have to leave her position. Consequently, both Ash and Garrett filed discrimination lawsuits against the University of Alabama in the United States District Court for the Northern District of Alabama. The plaintiffs sought monetary damages under Title I of the Americans with Disabilities Act (ADA) of 1990. The ADA specifically prohibited states and employers from “discriminating against a qualified individual with a disability because of that disability... in regard to... terms, conditions, and privileges of employment” (Oyez).
The University of Alabama responded to the lawsuit in the District Court with a motion to dismiss the case on the grounds that the Eleventh Amendment prohibited the plaintiffs claim. The United States District Court for the Northern District of Alabama agreed with the University of Alabama and dismissed the two discrimination lawsuits. The District Court agreed with the University of Alabama that “the ADA exceeds Congress’ authority to abrogate (repeal) the State’s Eleventh Amendment immunity” (Cornell).
Ash and Garrett appealed the United States District Court for the Northern District of Alabama to the United States Court of Appeals for the Eleventh Circuit. The Eleventh Circuit of Appeals reversed the District Court’s decision on the grounds that “the ADA validly abrogates such immunity” (Cornell).
As a result of the Eleventh Circuit of Appeals ruling, the University of Alabama appealed to the U.S. Supreme Court who agreed to consider if an individual can sue a state for damages in federal court the ADA of 1990. In a contentious 5-4 ruling, Chief Justice William Rehnquist wrote that state employees cannot sue their state employers for monetary damages under the ADA because Congress lacked the authority to override states’ sovereign immunity under the Eleventh Amendment.
Chief Justice Rehnquist reasoned that “in order to authorize private individuals to recover money damages against the States, there must be a pattern of discrimination by the States which violates the Fourteenth Amendment, and the remedy imposed by Congress must be congruent and proportional to the targeted violation" (Oyez). Meaning, even though Congress could enforce the Fourteenth Amendment’s Equal Protection Clause, Congress must demonstrate a pattern of unconstitutional discrimination, in this case, by states against people with disabilities. This was true in cases such as City of Boerne v. Flores (1997), when Congress was able to enforce the Fourteenth Amendment’s Equal Protection Clause. However, in the Board of Trustees of University of Alabama v. Garret, the majority opinion said that part of the ADA lacked “congruence and proportionality" required when Congress exercises its enforcement power under the Fourteenth Amendment (Cornell). Consequently, the majority opinion concluded that Congress did not have sufficient evidence of unconstitutional state discrimination against disabled individuals to justify allowing private lawsuits for damages against states (Oyez).
Justice Stephen Breyer filed a dissenting opinion, which was joined by Justices John Paul Stevens, David Souter, and Ruth Bader Ginsburg. Justice Breyer argued that Congress had ample evidence of unconstitutional discrimination against people with disabilities by state governments in this case, which justified allowing lawsuits against states under the ADA. Justice Breyer expressed concern that the majority’s ruling would undermine Congressional authority to protect vulnerable populations and weaken civil rights protections by giving states immunity from liability for violating federal disability rights laws.
Further, Justice Breyer criticized the majority opinion through rational-basis review. Justice Breyer argued, “Although ‘negative attitudes’ and ‘fear’ often accompany irrational biases, their presence alone does not a constitutional violation make. Thus, the Fourteenth Amendment does not require States to make special accommodations for the disabled, so long as their actions toward such individuals are rational.” Meaning, Justice Breyer is advocating for legal protections for disabilities to come from “positive law and not through the Equal Protection Clause” (Cornell).
Furthermore, Justice Breyer cited City of Cleburne v. Cleburne Living Center, Inc (1985) and Katzenbach v. Morgan (1966) as precedents regarding the “congruence and proportionality” standard applied by the majority. Justice Breyer criticized the majority for imposing overly rigid standards and said that the Court should defer to Congress’s judgment in identifying and remedying constitutional violations, as was true in these precedents.
Impact
There were two primary impacts from the Board of Trustees of University of Alabama v. Garrett (2001). First, the Supreme Court’s ruling limited the ADA’s applications to state governments, essentially meaning they had sovereign immunity in cases where state employees sought monetary damages for ADA violations. Second, the Supreme Court’s significantly limited Congressional power under Section 5 of the Fourteenth Amendment to enforce equal protection guarantees against states (Legal Momentum).
Court Documents
Citations
Board of Trustees of the University of Alabama v. Garrett, Legal Momentum, www.legalmomentum.org/amicus-briefs/board-trustees-university-alabama-v-garrett. Accessed 3 Feb. 2025.
“Board of Trustees of Univ.. of Ala.v. Garrett.” Legal Information Institute, Cornell Law School, 21 Feb. 2001, www.law.cornell.edu/supct/html/99-1240.ZS.html.
"Board of Trustees of University of Alabama v. Garrett." Oyez, www.oyez.org/cases/2000/99-1240. Accessed 2 Feb. 2025.
