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United States v. Georgia (2006)

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  • 3 min read

By: Kacie Matthews




Overview


United States v. Georgia (2006) was a Supreme Court Case that involved three parties: Tony Goodman, the state of Georgia, and the United States. Tony Goodman was a paraplegic; paralyzed from the waist down due to multiple spinal fractures. Goodman sued the Georgia State Prison system, claiming that the prison held conditions that discriminated against him, and all disabled people. Goodman stated that this went against the Americans with Disabilities Act of 1990 (ADA) as the prison had inaccessible features, exclusion, and medical neglect. Additionally, Goodman sued the Georgia State Prison under the violation of the Eighth Amendment which prohibits excessive bail, excessive fines, and cruel and unusual punishment. Georgia and the United States later responded. 



Summary


Tony Goodman sued the Georgia prison system under the conditions he faced: 

1) Confinement: Goodman was a paraplegic; a man in a wheelchair,  and being locked in a 12 by 3 foot prison cell for 24 hours a day limited his mobility.

2) Inaccessible Features: Georgia’s state prison system lacked wheelchair accessible toilets and showers, therefore, Goodman wasn’t able to shower, and often found himself sitting in his own feces for long periods of time.

3) Injuries: Goodman was not able to move on his own, and required physical assistance to be transported from his wheelchair to the toilet or shower. However, he never received assistance from prison guards or helpers. Therefore, Goodman resorted to trying to move himself off his wheelchair into the toilet or shower, and often didn’t succeed resulting in physical injuries. 

4) Medical Neglect: As Goodman received these physical injuries from a lack of help from prison guards, and his own effort to use the bathroom or shower, he needed medical help. However, once again, the Georgia State Prison rejected his request for medical assistance, and never provided Goodman with the disability assistance needed. Examples of the disability assistance Goodman asked for include medical help for bedsores, and catheters.

5) Exclusion: Lastly, as Goodman was in a wheelchair, he was excluded from prison programs, classes, and everyday activities the prison originally entitled every prisoner to. 


The state of Georgia responded to Goodman’s case, and although Goodman sued the Georgia State Prison in violation of Title II in ADA, Georgia responded citing the Eleventh Amendment. Georgia argued that the Eleventh Amendment protects U.S states from being sued by individuals at the federal level. Georgia believed that the Eleventh Amendment provided state sovereignty immunity regardless of the case. However, within Title II of ADA, it specifically mentions that Congress has the ability to remove state sovereignty immunity and allows individuals to sue states regarding disability discrimination, as in Tony Goodman’s case. 


The Supreme Court became involved to determine whether Georgia could claim sovereign immunity against Goodman’s ADA claims, and in a unanimous decision of 9-0, the Supreme Court sided with Goodman. Firstly, the Supreme Court held that states are not protected by sovereign immunity when alleged ADA violations also constitute violations of the Fourteenth Amendment. Secondly, Georgia State Prison violated specific articles within the Eighth Amendment. Goodman accused the prison of cruel and unusual punishment, which was found evidential of multiple violations on Georgia State Prison’s side.  



Impact


United States v. Georgia held a significant change for all disabled individuals: allowing them to hold state systems accountable, and sue them if one believes they violate the ADA. United States v. Georgia clarified that Congress may remove state sovereign immunity in certain ADA cases involving constitutional violations. The Supreme Court and Congress hold civil rights over states, and can limit disability discrimination.



Court Documents



Citations

United States v. Georgia, Oyez, https://www.oyez.org/cases/2005/04-1203


 
 
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