Board of Trustees of the University of Alabama v. Garrett

From Academic Kids

Board of Trustees of the University of Alabama v. Garrett, 531 U.S. 356 (2001), was a United States Supreme Court case the determined that the Congress's enforcement powers under the Fourteenth Amendment to the Constitution did not extend to the abrogation of state sovereign immunity under the Eleventh Amendment where the discrimination complained of was based on disability.



The plaintiffs were Milton Ash and Patricia Garrett, employees of the University of Alabama school system. Both were disabled under the definition of the Americans with Disabilities Act (ADA): Ash had a lifelong history of severe asthma, and Garrett had been diagnosed with breast cancer, and had received radiation and chemotherapy treatments. Both alleged that they had been discriminated against at their jobs, and filed a suit in federal court against the University of Alabama for money damages, arguing that the University had violated Title I of the ADA.

The University of Alabama responded with a motion to dismiss on the grounds that the Eleventh Amendment prohibited the suit. The United States District Court dismissed both cases on this ground, but the Eleventh Circuit reversed, holding that Congress had expressly abrogated the sovereign immunity of the states.


Was Congress able to abrogate the immunity of the states under its Fourteenth Amendment power to enforce the Equal Protection Clause?


The Court, in an opinion by Chief Justice William Rehnquist, held that Congress, in the legislative record of the ADA, failed to show a pattern of state discrimination against Americans with disabilities that rose to the level of irrationality. (Under the Fourteenth Amendment, the Court held, only irrational discrimination against the disabled was prohibited. See Equal Protection Clause.) And (the Court said) since citizens' substantive rights under the Fourteenth Amendment are determined by the Supreme Court alone, Congress cannot remedy violations of rights where those rights do not exist. Thus, the ADA did not meet the congruent-and-proportional test of City of Boerne v. Flores, and so unconstitutionally abrogated the states' sovereign immunity.


The Court had split 5-4, with Justice Stephen Breyer filed a dissenting opinion in which he was joined by Justices John Paul Stevens, David Souter, and Ruth Bader Ginsburg. The dissent argued that Congress had indeed met the congruent-and-proportional test, noting that even though disparate treatment based on disability is subject only to rational review, Congress nevertheless had the power to protect the handicapped from distinctions made with no rational basis.


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