Board of Trustees of Univ. of Ala. v. Garrett

2001-02-21

Headline: Court bars state employees from suing states for money damages under Title I of the ADA, limiting the ability of state workers to recover federal monetary relief for workplace disability claims.

Holding: We hold that private employees may not recover money damages from States under Title I of the ADA because the Eleventh Amendment bars those suits and Congress did not validly abrogate state immunity under its Fourteenth Amendment enforcement power.

Real World Impact:

Prevents state employees from getting money damages in federal court under Title I of the ADA.
Leaves injunctive relief and federal government enforcement as enforcement options against States.
Encourages reliance on state laws and remedies for workplace disability discrimination.

Topics: disability discrimination, state immunity, employee lawsuits, federal enforcement

Summary

Background

Two Alabama state employees — Patricia Garrett, a nurse who lost her director job after cancer treatment, and Milton Ash, a security officer denied work changes for asthma and sleep apnea — sued their state employers for money damages under Title I of the Americans with Disabilities Act (ADA). The District Court agreed with the State and dismissed the suits; the Eleventh Circuit reversed; the Supreme Court granted review to resolve a split among appeals courts.

Reasoning

The Court asked whether Congress validly removed the States' immunity from private money-damage suits under the Eleventh Amendment by using its enforcement power in §5 of the Fourteenth Amendment. The majority held Congress did not do so. The opinion reasons that the ADA’s legislative record did not show a sufficient pattern of unconstitutional state employment discrimination and that the ADA’s remedies were not sufficiently congruent and proportional to any such pattern. The Court relied on prior decisions (including Cleburne and City of Boerne) to explain why private money claims against States exceed what §5 permits here.

Real world impact

As a result, private state employees cannot recover money damages from States in federal court under Title I. The opinion notes Title I standards still exist: the United States can sue for money damages, private plaintiffs can seek injunctive relief against state officials under Ex parte Young, and state laws may offer separate remedies. The Court also dismissed the separate Title II question as improvidently granted.

Dissents or concurrances

Justice Kennedy (joined by Justice O’Connor) wrote a short concurrence emphasizing prejudice but joined the judgment. Justice Breyer (joined by Stevens, Souter, and Ginsburg) dissented, arguing Congress had a robust record and deserved deference to enact Title I remedies against States.