Olmstead v. L.C. (1999)
- Sam Shepherd
- Oct 21, 2024
- 5 min read
By Nicole Tursellino
Overview
Olmstead v. L.C., 527 U.S. 581 (1999) brought to light whether or not financial limits are the sole determining factor in whether or not a state chooses to comply with the 1990 Americans with Disabilities Act (ADA) in community based programs that assist individuals that possess disabilities. The Supreme Court found in a 6-3 decision, with a majority opinion given by Ruth Bader Ginsburg, that the two plaintiffs, Lois Curtis and Elaine Wilson, were wrongly subjected to institutionalization as a result of their disabilities; this showed that states were ultimately required to out individuals who had mental disabilities into community centers rather than institutions (depending on factors such as professional placement opinions and that placement can be accommodate in a reasonable manner). The state, though, is at their discretion to assess their financial circumstances and to make determinations in regards to whether or not the placement of a certain individual would harm others in the facility in which they are placed, and to take these considerations into consideration.
Summary
Lois Curtis and Elaine Wilson were two individuals living in the state of Georgia that had voluntarily admitted themselves into a psychiatric facility at Georgia Regional Hospital to receive help for their mental disabilities. Curtis had been diagnosed with schizophrenia and Wilson was diagnosed with a personality disorder. For Lois Curtis, after being institutionalized and found to be in a stable condition, Georgia Regional Hospital agreed to discharge Curtis to a community-based facility funded by the state of Georgia; however, Curtis remained institutionalized for three years after this decision, and she was eventually placed into the community-based program in 1996. For Elaine Wilson, Georgia Regional Hospital initially wanted to place her in a homeless shelter upon her discharge, but with the help of an attorney, she was able to be placed into a community-based facility as well. However, much like Curtis, after being found fit to be released from the institutionalized setting into a community-based one, Wilson remained at Georgia Regional Hospital for months before being discharged.
The District Court found that Curtis and Wilson had been discriminated against for their mental disabilities by the state of Georgia, since the doctors had concluded that they were mentally fit to be placed in community-based programs and failed to effectively mobilize these patients to these facilities, ultimately leaving them to live in conditions that were much more restrictive in the institutionalized setting. The District Court also found that this discrimination could not be held because of a “lack of funding.” The Eleventh Circuit Court of Appeals agreed with the decision upheld by the District Court, which affirmed the decision.
When this case made its way to the Supreme Court’s docket, the Court stood to answer the question of whether the ADA’s “integration mandate,” a mandate that requires the state to provide individuals with disabilities services and programs most fit for the individuals needs, was violated by the state when they did not place these two women into the adequate facility for their needs. The Court ruled in a 6-3 decision in favor of Curtis and Wilson, stating that Georgia had discriminated against the women by institutionalizing these individuals after it had been determined that full integration in an institution was not necessary based on their mental conditions. With this, the court stated that once an individual had been cleared to move from the institutionalized setting to a different “integrated setting” by medical professionals, along with the individual expressing a desire to move to a different setting and the state having suitable resources to make the transfer of the patient possible, then the state was required to make accommodations and do so.
Impact
Olmstead v. L.C., 527 U.S. 581 (1999) was a monumental case for individuals who had disabilities, specifically mental disabilities. In the case assessment of the ADA, it allowed for individuals with disabilities to be integrated into community-based facilities without discrimination because of the disabilities in which they possessed. As a result of this, states have changed the way in which they interpret the ADA, and states have learned to treat individuals with mental disabilities in a way that follows the guidelines of this act. Not only has it set a legal precedent for court rulings regarding the interpretation of the ADA, but it has also served as a monumental case for individuals with mental disabilities that have entered into the Supreme Court after its ruling in 1999. Some of these cases include, but are not limited to: Tennessee v. Lane, 541 U.S. 509 (2004); Chevron U.S.A. Inc. v. Echazabal, 536 U.S. 73 (2002); U.S. Airways, Inc. v. Barnett, 535 U.S. 391 (2002). In these cases, Olmstead served as a principle in assessing the ways in which individuals who possessed disabilities could not be discriminated against as well as in interpreting the writing of the ADA.
Many states, as a result of this case, have worked to expand their community- based services and programs, with a heightened increase in funding and overall support for them. More specifically, it has had implications on Medicaid and the ways in which it is applied to services. After the ruling in Olmstead, Medicaid shifted its balance from providing funding through long-term services and support to “greater community integration through home- and community- based services” (MACPAC). With this, there has been a rise in both federal and state efforts to serve beneficiaries in communities who use long-term services and support.
Additional Documents
To listen to the Oral Arguments given on April 21, 1999, click here: https://www.oyez.org/cases/1998/98-536
To listen to the Opinion Announcement given on June 22, 1999, click here: https://www.oyez.org/cases/1998/98-536
To read more about the Opinions and Dissents, click here:
To read more about Title II of the 1990 Americans with Disabilities Act, click here: https://www.ada.gov/topics/title-ii/#:~:text=Title%20II%20of%20the%20ADA,programs%2C%20services%2C%20and%20activities.
To read personal stories about individuals lives who have been impacted as a result of the decision found in this case, click here:
For more information about the Georgia Department of Human Services, click here: https://dhs.georgia.gov/
To learn more about Tennessee v. Lane, 541 U.S. 509 (2004), click here:
To learn more about Chevron U.S.A. Inc. v. Echazabal, 536 U.S. 73 (2002), click here:
To learn more about the case U.S. Airways, Inc. v. Barnett, 535 U.S. 391 (2002), click here:
Citations
Advising Congress on Medicaid and CHIP Policy. MACPAC, 2019, www.macpac.gov/wp-content/uploads/2019/07/Twenty-Years-Later-Implications-of-Olmstead-on-Medicaids-Role-in-LTSS.pdf.
Chevron U.S.A. Inc. v. Echazabal, 536 U.S. 73 (2002)
1990 Americans with Disabilities Act (ADA)
Olmstead v. L.C., 527 U.S. 581 (1999)
Tennessee v. Lane, 541 U.S. 509 (2004)
U.S. Airways, Inc. v. Barnett, 535 U.S. 391 (2002)
U.S. Department of Labor. “Americans with Disabilities Act.” Dol.gov, U.S. Department of
Labor, 2024, www.dol.gov/general/topic/disability/ada.
U.S. Department of Justice Civil Rights Division. “ADA.gov.” Ada.gov, 2024, www.ada.gov/.