Eichenlaub v. Shaughnessy
338 U.S. 521 (1950)
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Rule of Law:
Section 504 of the Rehabilitation Act of 1973 protects individuals with contagious diseases from discrimination if they are otherwise qualified for their position. An individualized inquiry based on reasonable medical judgments is required to determine whether such an individual is otherwise qualified.
Facts:
- Gene Arline was hospitalized for tuberculosis in 1957, after which the disease was in remission for 20 years.
- From 1966 to 1979, Arline was employed as an elementary school teacher by the School Board of Nassau County, Florida.
- In 1977, a culture revealed Arline's tuberculosis was again active.
- Arline suffered two more relapses of tuberculosis in the spring and fall of 1978.
- Following her third relapse within two years, the School Board discharged Arline at the end of the 1978-1979 school year.
- The School Board stated the dismissal was not for any wrongdoing but because of the continued recurrence of her tuberculosis.
Procedural Posture:
- After being discharged, Gene Arline was denied relief in state administrative proceedings.
- Arline sued the School Board in the U.S. District Court, alleging a violation of § 504 of the Rehabilitation Act.
- The District Court, a trial court, ruled against Arline, holding that a contagious disease is not a 'handicap' under the Act and that, even if it were, Arline was not 'otherwise qualified' for her job.
- Arline, as appellant, appealed to the U.S. Court of Appeals for the Eleventh Circuit.
- The Court of Appeals, an intermediate appellate court, reversed the District Court, holding that the Act does cover individuals with contagious diseases.
- The Court of Appeals remanded the case to the District Court for further findings on whether Arline was 'otherwise qualified.'
- The School Board, as petitioner, successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does Section 504 of the Rehabilitation Act of 1973 protect an employee from being discharged due to a contagious disease like tuberculosis?
Opinions:
Majority - Justice Brennan
Yes, Section 504 of the Rehabilitation Act protects an employee from being discharged due to a contagious disease if they are otherwise qualified. Arline's hospitalization for tuberculosis established a 'record of impairment,' bringing her within the Act's definition of a 'handicapped individual.' The Court reasoned that the contagious effects of a disease cannot be meaningfully distinguished from the disease's physical effects on the individual, as both stem from the same underlying condition. To allow discrimination based on contagiousness would undermine the Act's purpose, which is to protect individuals from decisions based on prejudice, stereotypes, and irrational fears. The court remanded the case for an individualized inquiry into whether Arline was 'otherwise qualified,' which requires assessing the health risks based on reasonable medical judgments and determining if a reasonable accommodation could be made.
Dissenting - Chief Justice Rehnquist
No, Section 504 of the Rehabilitation Act was not intended to protect individuals from discrimination based solely on the contagious nature of their disease. The dissent argued that Arline was discharged because of the threat her contagiousness posed to the health of others, not because of any diminished physical or mental capability to perform her job. Citing Pennhurst, the dissent contended that Congress must speak unambiguously when imposing conditions on federal funds, and the Act is silent on whether contagiousness constitutes a handicap. Extending the Act to cover public health concerns would improperly alter the federal-state balance without a clear expression of congressional intent.
Analysis:
This landmark decision significantly broadened the scope of federal disability law by establishing that contagious diseases can be considered handicaps under the Rehabilitation Act. It shifted the legal focus from whether a person is covered by the Act to the more fact-intensive inquiry of whether they are 'otherwise qualified' and can be 'reasonably accommodated.' This ruling set a crucial precedent for future cases involving communicable diseases, most notably HIV/AIDS, by mandating that employment decisions be based on individualized scientific assessments rather than on generalized fears or stereotypes.
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