Southeastern Community College v. Davis
442 U.S. 397 (1979)
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Rule of Law:
Section 504 of the Rehabilitation Act of 1973 does not require an educational institution to lower or make substantial modifications to its standards to accommodate a handicapped person. An "otherwise qualified" individual is one who can meet all of a program's requirements, including legitimate physical qualifications, in spite of their handicap.
Facts:
- Frances Davis, who had a serious hearing disability requiring her to rely on lipreading, applied for the Associate Degree Nursing program at Southeastern Community College.
- Southeastern Community College is a state institution that receives federal funds.
- An audiologist's examination confirmed that Davis's hearing loss meant she could not understand speech without lipreading.
- The nursing program at Southeastern required clinical training where doctors and nurses often wear surgical masks, which would make lipreading impossible.
- The Executive Director of the North Carolina Board of Nursing recommended that Davis not be admitted, concluding her hearing disability would make it unsafe for her to practice as a nurse and participate in the clinical training program.
- After consultation and deliberation, Southeastern's nursing staff denied Davis admission to the program due to her hearing disability and the potential danger to patients.
Procedural Posture:
- Frances Davis filed suit against Southeastern Community College in the United States District Court for the Eastern District of North Carolina.
- After a bench trial, the District Court entered judgment in favor of Southeastern, concluding Davis was not an 'otherwise qualified' individual under § 504.
- Davis, as the appellant, appealed the decision to the United States Court of Appeals for the Fourth Circuit.
- The Court of Appeals reversed the District Court's judgment, holding that Davis's handicap should not have been considered in determining if she was 'otherwise qualified'.
- Southeastern Community College, as the petitioner, successfully sought a writ of certiorari from the U.S. Supreme Court.
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Issue:
Does § 504 of the Rehabilitation Act of 1973 forbid a professional school from imposing physical qualifications for admission to its clinical training programs and denying admission to an applicant who cannot meet those qualifications?
Opinions:
Majority - Justice Powell
No. Section 504 of the Rehabilitation Act of 1973 does not forbid a professional school from considering a disability that would prevent an applicant from meeting the program's legitimate physical requirements. The court reasoned that the statutory language of an "otherwise qualified handicapped individual" refers to one who is able to meet all of a program's requirements in spite of their handicap, not an individual who would be qualified but for their handicap. The Court distinguished § 504's non-discrimination mandate from the explicit "affirmative action" requirements found in other sections of the Act, such as § 501 and § 503. It concluded that § 504 does not compel educational institutions to make substantial modifications to their programs or to disregard the disabilities of applicants, as doing so would constitute an unauthorized extension of the obligations imposed by the statute. Therefore, Southeastern was not required to fundamentally alter its nursing program or lower its standards to accommodate Davis.
Analysis:
This case provided the Supreme Court's first interpretation of § 504 of the Rehabilitation Act, establishing a crucial precedent in disability law. The Court's narrow definition of an "otherwise qualified" person placed the initial burden on the individual to meet existing program standards, rather than requiring institutions to fundamentally alter their programs. This decision distinguished between non-discrimination and affirmative action, setting a limit on the scope of accommodations required under the Act. It affirmed that institutions can maintain legitimate physical requirements essential to a program, a principle that would influence the later development of the "reasonable accommodation" standard under the Americans with Disabilities Act (ADA).
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