County of Los Angeles Et Al. v. Kling

Background

Mary Kling applied to the Los Angeles County School of Nursing. She suffers from Crohn’s disease. The school’s physician concluded the program would be too stressful and she was denied admission. The District Court found she had not proved she was denied admission solely because of her illness and denied relief under Section 504 of the Rehabilitation Act. The Ninth Circuit reversed, finding Kling an otherwise qualified disabled person denied admission because of her handicap.

Reasoning

The Supreme Court granted review and issued a summary reversal of the Ninth Circuit’s judgment, citing Anderson v. Bessemer City. The Court did not provide a full written review of the trial record in this summary disposition. Justice Stevens, joined by Justice Brennan, criticized the Court for reversing without reviewing the record and for the brief, unpublished handling of the Ninth Circuit’s earlier opinion. Justice Marshall separately dissented from the summary procedure because the parties were not given prior notice or a chance to file merits briefs.

Real world impact

The immediate result is that the Ninth Circuit’s ruling in Kling’s favor was overturned, removing that appellate victory for the nursing applicant. The summary nature of the reversal also drew sharp dissents and raises concerns about the Court’s practice of deciding some appeals without full briefing or record review. The case highlights tensions over unpublished appellate opinions and the Supreme Court’s use of summary dispositions.

Dissents or concurrances

Justices Stevens and Brennan argued the Court should have reviewed the record and explained its decision; Justice Marshall objected to the lack of notice and briefing.