United States v. Georgia
The Court ruled that a paraplegic Georgia inmate could sue the state for money damages under the disability-rights law, at least for the parts of his claim that also amounted to actual violations of his constitutional rights.
The decision confirms that Congress can strip states of their usual immunity from lawsuits when a law is being used to remedy real constitutional violations, but leaves open whether Congress can go further and require damages for conduct that violates only the disability law itself.
“Thus, insofar as Title II creates a private cause of action for damages against the States for conduct that actually violates the Fourteenth Amendment, Title II validly abrogates state sovereign immunity.”
The Court's central holding on when the disability-rights law can override a state's immunity from lawsuits.
How it got here: A federal trial court dismissed Goodman's civil-rights claims and granted Georgia summary judgment on his disability-law damages claims; the Eleventh Circuit reversed in part, and both sides sought Supreme Court review.
The Case in Depth
What happened
Tony Goodman, a paraplegic inmate in a Georgia prison, said he was confined nearly 24 hours a day in a cell too small to turn his wheelchair, was denied help using the toilet or shower, was left to sit in his own waste, and was denied medical care and access to prison programs because of his disability. He sued Georgia and prison officials for money damages under both a civil rights law and the Americans with Disabilities Act.
The question before the Court
Could a paralyzed state prison inmate sue Georgia for money damages under the Americans with Disabilities Act, even though states normally can't be sued without their consent?
The Court's answer
Yes — the Court ruled that a disabled inmate can sue a state for money damages under the Americans with Disabilities Act's Title II, at least for the portions of his claim that also amount to actual violations of the Constitution. Because Georgia did not dispute that the mistreatment Goodman described (denied bathroom access, being left in his own waste, lack of medical care) also violated the Eighth Amendment, the Court held Congress validly stripped the state of its normal immunity from being sued for that conduct.
The Court did not go further to decide whether states can also be sued under the ADA for conduct that violates the disability law but not the Constitution itself — that harder question was left for the lower courts to work out once Goodman's claims are spelled out in more detail on remand.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Disabled state prisoners nationwide gain a clearer path to sue for damages when prison mistreatment also violates the Constitution, not just the ADA. State corrections departments face renewed exposure to lawsuits over inaccessible facilities and denied care. Lower courts must now sort case-by-case which claims rest on constitutional violations versus ADA-only violations.
What changes now
The case goes back to the lower courts, where Goodman will amend his complaint to spell out his claims in more detail. The trial court and appeals court must then decide, claim by claim, which of his allegations describe actual constitutional violations (letting his damages claims proceed) and which rest only on the disability-rights law itself — a harder question the Supreme Court left unresolved for now.
What this does not decide
The Court did not decide whether the disability-rights law can strip states of immunity for conduct that violates the ADA but does not independently violate the Constitution. That harder question — how far Congress can go using only its power to prevent future violations — is left for the lower courts to address once the facts are more fully developed.
Concurrences and dissents
Concurrence — Justice Stevens
Justice Stevens joined the Court's opinion but stressed that Goodman's Eighth Amendment claims were not meant to be the only constitutional rights relevant to disabled prisoners' cases. He noted that the historical record supporting the disability-rights law's protections for inmates covered far more than cruel-and-unusual-punishment claims, including religious liberty, court access, and due process violations, and that lower courts should keep this broader context in mind on remand.
How the Court got there
The legal reasoning, step by step
- The Court had already assumed, without deciding, that Goodman's allegations described actual violations of the Eighth Amendment's ban on cruel and unusual punishment, since the appeals court found his claims sufficient and Georgia did not contest that finding.
- Because Georgia did not dispute that this same mistreatment also violated the disability-rights law's ban on excluding disabled people from prison programs and services, the Court treated Goodman's money-damages claims as resting, at least partly, on conduct that independently violated the Fourteenth Amendment.
- The Court explained that the Fourteenth Amendment gives Congress clear power to create lawsuits for damages against states when the conduct actually violates that Amendment's protections — including the Eighth Amendment's protections, which apply to the states through it.
- Applying that principle, the Court held that whenever the disability-rights law lets someone sue for damages over conduct that actually violates the Constitution, that part of the law validly strips states of their normal immunity from suit.
- Because the record did not make clear which of Goodman's specific allegations amounted to constitutional violations and which rested only on the disability-rights law's broader protections, the Court left it to the lower courts to sort that out claim by claim after Goodman amends his complaint.
Doctrinal impact
Cases affected by this decision
Distinguishes Tennessee v. Lane (541 U. S. 509)
Unlike Lane's claimants, Goodman actually alleged real constitutional violations, not just unequal treatment.
Distinguishes Board of Trustees of Univ. of Ala. v. Garrett (531 U. S. 356)
Garrett's plaintiffs faced no unconstitutional conduct, while Goodman's allegations did.