School Bd. of Nassau Cty. v. Arline
Headline: Ruling says teachers with contagious tuberculosis can be protected as disabled under federal law, reversing a blanket exclusion and sending the case back to decide if the teacher could safely keep teaching.
Holding:
- Allows employees with contagious illnesses to claim discrimination protections under federal disability law.
- Requires individualized medical fact-finding before employers can bar contagious workers from jobs.
- Permits employers to exclude workers when reasonable accommodations cannot eliminate serious health risks.
Summary
Background
Gene Arline was an elementary school teacher in Nassau County, Florida, from 1966 until 1979. After a third relapse of tuberculosis within two years, the school board discharged her because of the recurring illness. Arline sued under Section 504 of the Rehabilitation Act, arguing that she was dismissed solely because of her illness and therefore discriminated against as a handicapped person. The District Court rejected her claim; the Court of Appeals reversed and remanded for further findings.
Reasoning
The Supreme Court addressed two questions: whether a person with contagious tuberculosis can count as a handicapped individual under the Act, and whether Arline was “otherwise qualified” to teach. The Court found that tuberculosis affected Arline’s respiratory system and that her 1957 hospitalization gave her a record of impairment under the statute and regulations. The Court explained that contagiousness and the physical impairment stemmed from the same condition and that Congress intended to cover people harmed by others’ reactions as well as by physical limits. The Court held that a person with tuberculosis can be a handicapped individual and remanded for an individualized medical inquiry into risk, duration, severity, probability of transmission, and reasonable accommodation.
Real world impact
The ruling means employers and schools cannot categorically exclude people with contagious diseases without medical fact-finding and consideration of accommodations. Public-health judgments about real risks remain important: an employer may lawfully exclude a worker if reasonable accommodation cannot eliminate a significant health threat. The decision remanded Arline’s case for further factual findings rather than resolving whether she could have kept teaching.
Dissents or concurrances
Chief Justice Rehnquist (joined by Justice Scalia) dissented, arguing Congress did not clearly intend to regulate contagiousness under Section 504 and warning that the decision intrudes on public-health and state authority.
Opinions in this case:
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