Board of Trustees of Univ. of Ala. v. Garrett
The Supreme Court ruled that state employees cannot sue their state employer for money damages under Title I of the Americans with Disabilities Act, because Congress lacked the constitutional authority to strip states of their normal immunity from private damages suits in this context.
The decision means disabled state workers denied job accommodations must rely on other remedies -- like federal government enforcement or lawsuits seeking to stop ongoing discrimination -- rather than personal damages claims against the state itself.
“It is telling, we think, that given these large numbers, Congress assembled only such minimal evidence of unconstitutional state discrimination in employment against the disabled.”
The majority's central reason for finding the ADA's evidentiary record too thin to justify stripping states of immunity.
How it got here: A federal trial court granted summary judgment to the state on immunity grounds; the Eleventh Circuit reversed; the Supreme Court took the case to resolve a circuit split.
The Case in Depth
What happened
Patricia Garrett, a nurse at a University of Alabama hospital, was pushed out of her director position after taking leave for breast cancer treatment. Milton Ash, a security officer for an Alabama state agency, asked for workplace changes to manage his asthma and sleep apnea and was denied. Both sued the state under the ADA seeking money damages for disability discrimination in employment.
The question before the Court
Could disabled state employees sue their state government employer for money damages under the Americans with Disabilities Act?
The Court's answer
No — the Court ruled that Congress did not validly strip states of their normal immunity from private lawsuits when it made the ADA's employment provisions apply to state employers. Congress can only override that immunity through a proper exercise of its Fourteenth Amendment enforcement power, which requires proof of a real pattern of unconstitutional state discrimination and a remedy proportionate to that pattern.
The Court found the evidence Congress gathered showed only a handful of instances of actual state government discrimination against disabled employees, far too little to justify subjecting states to private damages suits, and found the ADA's accommodation and disparate-impact requirements went well beyond what the Constitution itself demands. So Alabama could not be sued for damages by Garrett and Ash, though other legal options against discrimination remained open to them.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
State and local government employees with disabilities who face workplace discrimination can no longer collect money damages directly from their state employer under the ADA. They can still seek injunctions to stop discrimination or rely on the federal government to sue on their behalf, but the practical avenues for individual compensation from state agencies narrow significantly.
What changes now
The ruling is final on the merits and reverses the Eleventh Circuit, restoring the states' immunity from private ADA damages suits under Title I. Disabled individuals retain other options, including suits for injunctive relief against individual state officials and enforcement actions brought by the federal government itself, along with any protections under state law. The decision does not affect ADA claims against local governments or private employers.
What this does not decide
The Court made clear its holding only bars private damages suits against states under Title I; it does not eliminate all recourse for disabled workers, since the federal government can still sue states for damages and individuals can still seek court orders stopping ongoing discrimination. The ruling also did not address Title II of the ADA, which the Court dismissed as improvidently granted.
Concurrences and dissents
Concurrence — Justice Kennedy
Justice Kennedy wrote separately to emphasize that prejudice against people with disabilities can stem from indifference or unconscious bias rather than only malice, and that the ADA reflects admirable social progress. But he stressed that finding a state 'in violation of the Constitution' requires real proof of purposeful discrimination, and that the absence of extensive court decisions finding states unconstitutionally mistreated the disabled confirmed no such pattern existed.
Dissent — Justice Breyer
“In my view, Congress reasonably could have concluded that the remedy before us constitutes an "appropriate" way to enforce this basic equal protection requirement. And that is all the Constitution requires.”The dissent's core disagreement over how much deference Congress deserves in enforcing equal protection.
Justice Breyer argued the majority wrongly treated Congress's legislative record like a court record requiring rigorous proof, when Congress is entitled to draw reasonable, general conclusions from a large volume of anecdotal evidence -- including roughly 300 examples of state-level disability discrimination -- without judicial-style scrutiny. He would have upheld the ADA's damages remedy as an appropriate exercise of Congress's power to enforce equal protection, faulting the majority for holding Congress to unreasonably strict evidentiary and tailoring standards.
How the Court got there
The legal reasoning, step by step
- The Court explained that Congress can only strip states of their normal immunity from private lawsuits (a protection tied to the Eleventh Amendment) when it acts under Section 5 of the Fourteenth Amendment, which lets Congress pass laws enforcing the Equal Protection Clause -- not when it merely relies on its general commerce power.
- To decide whether the ADA's damages remedy against states was valid Section 5 legislation, the Court first identified the underlying constitutional right: under existing equal protection case law (Cleburne v. Cleburne Living Center, a 1985 case involving a group home for people with intellectual disabilities), disability-based classifications by government only get the most lenient judicial review, called rational-basis review, meaning a state action is valid if there is any conceivable reasonable justification for it.
- Because only rational-basis review applies, the Court required Congress to show it had identified an actual pattern of irrational, unconstitutional discrimination against disabled people specifically by state governments (not just private employers or cities and counties) before it could impose a stronger damages remedy on states -- a requirement drawn from the 'congruence and proportionality' test, meaning the remedy must closely match the size and shape of the constitutional problem it addresses.
- Reviewing the ADA's legislative record, the Court found only about half a dozen examples of state (as opposed to local or private) employment discrimination against the disabled, and concluded this was far too thin a record to establish the kind of widespread unconstitutional state conduct that would justify subjecting states to private damages suits.
- The Court further found that the ADA's 'reasonable accommodation' and disparate-impact requirements go well beyond what rational-basis review would ever require of states, making the remedy too broad and mismatched relative to the limited evidence of actual constitutional violations by states.
- Because the evidentiary record was too thin and the remedy too disproportionate, the Court concluded that subjecting states to ADA damages suits was not valid legislation under Section 5, and therefore Congress had not properly stripped away the states' immunity from these private lawsuits.
Doctrinal impact
Cases affected by this decision
Reaffirms Cleburne v. Cleburne Living Center, Inc. (473 U.S. 432)
The Court relied on Cleburne's rational-basis framework as the controlling equal protection standard for disability classifications.
Reaffirms City of Boerne v. Flores (521 U.S. 507)
The Court applied City of Boerne's congruence-and-proportionality test to strike down the ADA's damages remedy against states.
Reaffirms Fitzpatrick v. Bitzer (427 U.S. 445)
The Court relied on Fitzpatrick's rule that Section 5 legislation can validly override state sovereign immunity.