Olmstead v. L.C.
144 L. Ed. 2d 540, 1999 U.S. LEXIS 4368, 119 S.Ct. 2176 (1999)
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Rule of Law:
Under Title II of the Americans with Disabilities Act, states are required to place persons with mental disabilities in community settings rather than institutions when the state's treatment professionals have determined community placement is appropriate, the transfer is not opposed by the affected individual, and the placement can be reasonably accommodated. Unjustified segregation of persons with disabilities constitutes discrimination in violation of the ADA.
Facts:
- L.C. and E.W. are two women with mental retardation and other psychiatric conditions.
- L.C. was voluntarily admitted to Georgia Regional Hospital (GRH), a state psychiatric institution, in May 1992.
- By May 1993, L.C.'s treatment team at GRH concluded that her needs could be appropriately met in a community-based program.
- Despite this professional determination, L.C. remained institutionalized at GRH until February 1996.
- E.W. was voluntarily admitted to GRH in February 1995.
- By 1996, E.W.'s treating psychiatrist also determined that she could be treated appropriately in a community-based setting.
- E.W. also remained institutionalized long after this determination was made.
- Neither L.C. nor E.W. opposed being transferred to a community-based setting.
Procedural Posture:
- L.C. filed suit against Georgia state officials in the U.S. District Court for the Northern District of Georgia, alleging violations of the ADA.
- E.W. intervened in the lawsuit, asserting an identical claim.
- The District Court granted partial summary judgment for L.C. and E.W., holding that the State's failure to place them in the community violated Title II of the ADA.
- The District Court rejected the State's argument that inadequate funding was a valid defense.
- The State, as petitioners, appealed to the U.S. Court of Appeals for the Eleventh Circuit.
- The Court of Appeals affirmed the District Court's ruling that the ADA imposes a duty to provide community-based care when deemed appropriate, but it remanded the case for the trial court to reassess the State's cost-based 'fundamental alteration' defense.
- The State petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.
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Issue:
Does the Americans with Disabilities Act's (ADA) prohibition of discrimination by public entities require states to place individuals with mental disabilities in community settings rather than institutions, when the state's treatment professionals have determined community placement is appropriate, the individuals do not oppose the transfer, and the placement can be reasonably accommodated?
Opinions:
Majority - Justice Ginsburg
Yes, under qualified circumstances. The unjustified institutional isolation of individuals with disabilities constitutes discrimination under Title II of the ADA. The court's reasoning is based on Congress's explicit finding in the ADA that 'segregation' is a form of discrimination, as it perpetuates unwarranted stereotypes and severely diminishes individuals' ability to participate in community life. The Attorney General’s 'integration regulation,' which requires services to be administered in 'the most integrated setting appropriate,' is a reasonable interpretation of the statute. However, a state's obligation is not limitless. A state may offer a 'fundamental alteration' defense, which requires consideration of the state's available resources, the needs of the entire population of persons with mental disabilities it serves, and whether the state has a comprehensive, effectively working plan for placing qualified individuals in less restrictive settings.
Concurring - Justice Stevens
Yes. Unjustified institutional isolation is discrimination under the ADA. The proper disposition is to simply affirm the judgment of the Court of Appeals, which correctly remanded the case for consideration of the state's affirmative defense. However, because there are not five votes for that outcome, I join the Court's judgment and Parts I, II, and III-A of its opinion.
Concurring - Justice Kennedy
Yes, but on a narrower theory of discrimination. A violation of the ADA could be shown if the plaintiffs prove that Georgia provides treatment in integrated settings for individuals with other medical problems of comparable seriousness but, without adequate justification, fails to do so for a class of mentally disabled persons. The Court must apply this decision with great deference to the medical judgments of treating physicians and the program funding decisions of state policymakers. The ADA should not be interpreted to incentivize states to move individuals into inappropriate or under-resourced community settings for fear of litigation.
Dissenting - Justice Thomas
No. The failure to immediately provide community placement due to limited resources does not constitute 'discrimination' under the traditional meaning of the term. Discrimination requires differential treatment between a member of a protected class and a similarly situated member of a non-protected class. Here, the alleged disparate treatment is among members of the same protected class—individuals with disabilities who are awaiting placement versus those who have received it. The majority's holding improperly expands the definition of discrimination to impose a federal standard of care on states and infringes on state sovereignty by dictating how states must allocate their public service resources.
Analysis:
This landmark decision established that Title II of the ADA contains an 'integration mandate,' making unjustified segregation of individuals with disabilities a form of prohibited discrimination. It fundamentally shifted the landscape of disability rights law, empowering individuals to challenge unnecessary institutionalization and compelling states to develop more community-based services. However, the Court balanced this mandate by recognizing a 'fundamental alteration' defense, which gives states significant leeway if they can demonstrate that the requested accommodation is unworkable given their budget and obligations to all other individuals with disabilities. This decision has been the legal bedrock for deinstitutionalization efforts across the United States for decades.
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