Southeastern Community College v. Davis (1979)
- Sam Shepherd
- Sep 16, 2024
- 5 min read
Updated: Oct 27, 2024
By Nicole Tursellino
Overview
In Southeastern Community College v. Davis, 442 U.S. 397 (1979), the United States Supreme Court ruled in an unanimous decision that an “otherwise qualified handicapped individual” specified by Section 504 of the Rehabilitation Act of 1973 essentially meant an individual who met all of a specific program’s requirements “in spite of his handicap” as opposed to “in every respect except as to limitations imposed by their handicap.”
Summary
Frances Davis was an individual who sought admission to the Southeastern Community College’s Nursing Program, a federally-funded state-institution that is located in Whiteville, North Carolina. Frances Davis possessed a severe hearing disability, one that could not be solely cured with the use of hearing-aid devices; this left her relying on the practice of lip-reading to understand when individuals were directly communicating with her. The Southeastern Community College denied admission to Ms. Davis on the premise that it “believed her hearing disability made it impossible for her to participate safely in the normal clinical training program or to care safely for patients.”
With this, Ms. Davis filed suit against the institution in Federal District Court, claiming that Southeastern Community College violated Section 504 of the Rehabilitation Act of 1973. According to the U.S. Department of Health and Services, under the discretion of this section of the national law, individuals who are deemed to be a qualified individual with disabilities (someone who possesses a physical or mental impairment which limits the individual from doing life activities) are protected from discrimination based on the disability in which they hold. The District Court ruled judgment in favor of the petitioner, Southeastern Community College, upholding that Ms. Davis did not qualify as an “otherwise qualified handicapped individual” in regards to federally funded programs “solely by reason of his handicap.”
This suit then proceeded to enter the Court of Appeals, where the facts of the case were upheld; however, the ruling on the matter was reversed. The Court of Appeals found that Southeastern Community College should be required to reconsider Ms. Davis’ application to the institution’s nursing program without regard to the hearing disability in which she possessed, confining the institution's inquiry of her application to the program in consideration of her “academic and technical qualifications.” The Court of Appeals also suggested in its reversal ruling that Section 504 of the Rehabilitation Act of 1973 required “affirmative conduct,” of the school, highlighting how the institution was inclined to make adjustments to its nursing program in a way that would be inclusive to those who do possess disabilities.
Though, upon the precedent set by the Federal District Court’s decision, the Supreme Court found in a unanimous decision, in favor of Southeastern Community College. In a majority opinion produced by Justice Lewis F. Powell Jr., the Court found that there was no violation of Section 504 of the Rehabilitation Act of 1973 when the institution did not grant admission to Ms. Davis. “Modifying the nursing program, by providing a sign language interpreter for the student, constituted a substantial change in the school’s program. Therefore, not providing such a modification was not discriminatory under Section 504, so said the court” (Rapp 9).
Impact
With the decision that was upheld by the Court, colleges and institutions of the like are not fundamentally required to alter or modify programs within the setting of academic teaching if such modifications require the program to undergo substantial administrative and admission-based requirements. Additions to the staff of the nursing program, such as with the addition of a sign-language interpreter, was considered to be a substantial change to Southeastern Community College’s program requirements.
Southeastern Community College v. Davis, 442 U.S. 397(1979) was the first case to enter the Supreme Court in regards to interpreting this section of the law. This decision brings to light the nuanced and detailed language of Section 504 of the Rehabilitation Act of 1973. The ruling in this case brings to light the definition of what it means to be considered an “otherwise qualified handicapped individual,” and shows how not qualifying as this can prevent individuals with disabilities that do not fall under this group from participating in certain programs that institutions may offer to prospective students.
This case was used in part to assist in the Supreme Court’s ruling of another case regarding the interpretation of the Rehabilitation Act of 1973 just a few years later, Alexander v. Choate, 469 U.S. 287 (1985). In Choate, the topic of whether Medicaid cutbacks impact on individuals who possessed disabilities was discriminatory. In interpreting the pre-existing precedent set in Davis, the Supreme Court used the principle that severe alterations to a program or special treatment of other individuals due to disabilities is not required by the law, leading to the ruling in Choate stating that “disparate impact must be kept “within manageable bounds” (Francis 192).
In summary, the Court’s ruling in Southeastern Community College v. Davis, 442 U.S. 397(1979) served as the first case in which the Supreme Court was called to interpret the language of Section 504 of the Rehabilitation Act of 1973. In highlighting that institutions can make reasonable changes, but not severe changes, the case called into question the boundaries of what is considered to be a “severe” change to an institutions administrative staff and program, as well as what constitutes an individual to be deemed as a “qualified” in having a disability in conjunction with a specific program. This case has served as a precedent for other cases that have entered into the Supreme Court’s docket regarding individuals with disabilities and interpretations of Section 504, providing guidance for the legal standards that are associated with these types of cases.
Additional Documents
To read the full Supreme Court Opinions and Dissents, click here:
To listen to the Oral Argument made on April 23, 1979, click here:
To learn more about Section 504 of the Rehabilitation Act of 1973, click here:
To learn more about the Southeastern Community College’s Accessibility Services, click here:
To read more about Southeastern Community College’s Accommodations Due to a Disability, click here:
To learn more about Alexander v. Choate, 469 U.S. 287 (1985), click here:
Citations
Francis, Leslie. “Debilitating Southeastern Community College v. Davis.” University of the District of Columbia Law Review, 31 Mar. 2020, digitalcommons.law.udc.edu/cgi/viewcontent.cgi?article=1292&context=udclr. Accessed 08 Sep. 2024.
Rapp, JoAnn M. “The Federal Legislative Mandates of Services to the Special Needs Postsecondary Student and the Implications for Today’s Professor.” ERIC, 31 Mar. 1994, eric.ed.gov/?id=ED376659. Accessed 08 Sep. 2024.
“Rehabilitation Act of 1973.” 29 U.S.C, Section 794.
“Section 504 of the Rehabilitation Act.” Your Rights Under Section 504 of the Rehabilitation Act, U.S. Department of Health and Human Services, June 2006, www.hhs.gov/sites/default/files/ocr/civilrights/resources/factsheets/504.pdf. Accessed 08 Sep. 2024.
Southeastern Community College v. Davis, 442 U.S. 397 (1997)
Southeastern Community College V. Davis, 442 U.S. 397 (1979) | Findlaw, caselaw.findlaw.com/court/us-supreme-court/442/397.html. Accessed 08 Sep. 2024.
