United States v. Georgia
546 U.S. 151 (2006)
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Rule of Law:
Title II of the Americans with Disabilities Act (ADA) validly abrogates state sovereign immunity, allowing private suits for monetary damages against a State, insofar as the claims are based on conduct that independently constitutes a violation of the Fourteenth Amendment.
Facts:
- Tony Goodman, a paraplegic inmate in the Georgia state prison system, was confined for 23-to-24 hours a day in a cell so small he could not turn his wheelchair.
- The prison's toilet and shower facilities were not wheelchair accessible, rendering Goodman unable to use them without assistance.
- Prison officials frequently denied Goodman assistance, which on several occasions forced him to sit in his own feces and urine.
- Goodman injured himself on multiple occasions while attempting to transfer from his wheelchair to the toilet or shower without assistance.
- Goodman was also denied physical therapy, medical treatment, and access to nearly all prison programs and services on account of his disability.
Procedural Posture:
- Tony Goodman filed a pro se complaint in the U.S. District Court for the Southern District of Georgia against the State of Georgia and other defendants, seeking damages under Title II of the ADA and 42 U.S.C. § 1983.
- The District Court granted summary judgment to the state defendants on the Title II claims for money damages, holding that the claims were barred by Eleventh Amendment sovereign immunity.
- Goodman appealed to the U.S. Court of Appeals for the Eleventh Circuit, and the United States intervened to defend Title II's constitutionality.
- The Eleventh Circuit affirmed the district court's sovereign immunity holding, barring Goodman's Title II claims for money damages against the State.
- The U.S. Supreme Court granted certiorari to consider whether Title II validly abrogates state sovereign immunity for the claims at issue.
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Issue:
Does Title II of the Americans with Disabilities Act validly abrogate state sovereign immunity, allowing a state prisoner to sue the state for money damages for conduct that also violates the Fourteenth Amendment?
Opinions:
Majority - Justice Scalia
Yes. Title II of the ADA validly abrogates state sovereign immunity for conduct that actually violates the Fourteenth Amendment. Congress has the power under Section 5 of the Fourteenth Amendment to create private remedies against states for actual constitutional violations. This enforcement power includes abrogating state sovereign immunity for such claims. Goodman's allegations, which the lower court determined were sufficient to state a claim for Eighth Amendment violations (incorporated through the Fourteenth Amendment), also formed the basis of his Title II claim. Therefore, to the extent Title II provides a cause of action for conduct that itself violates the Constitution, the abrogation of sovereign immunity is valid. The case is remanded for the lower courts to determine on a claim-by-claim basis: (1) which aspects of the State’s conduct violated Title II; (2) to what extent that conduct also violated the Fourteenth Amendment; and (3) for any conduct that violated Title II but not the Fourteenth Amendment, whether the abrogation of immunity is nevertheless valid.
Concurring - Justice Stevens
Yes. The majority is correct to hold that Title II validly abrogates sovereign immunity for conduct that violates the Constitution and to remand the case for further proceedings. It is important to emphasize that the analysis on remand should not be limited to Goodman's Eighth Amendment claims. The lower courts should analyze all of Goodman's claims to see if they state violations of any constitutional provision, not just the Eighth Amendment, as prisoners retain a 'constellation of rights' such as due process and access to the courts. The Eleventh Circuit erred by limiting its inquiry to only the Eighth Amendment, and the remand provides an opportunity for the lower courts to properly apply the 'congruence and proportionality' framework from City of Boerne.
Analysis:
This decision provides a clear pathway for individuals to sue states for damages under federal civil rights statutes like the ADA by tying the statutory claim to an actual constitutional violation. The Court affirmed that Congress's Section 5 enforcement power is at its strongest when providing remedies for conduct that independently violates the Fourteenth Amendment. By remanding, the Court created an 'as-applied' challenge framework, allowing lower courts to validate the ADA's abrogation of immunity on a case-by-case basis rather than deciding the constitutionality of the entire statute's abrogation in all contexts. This leaves open the question of whether Title II's abrogation is valid for conduct that is merely statutory discrimination, not rising to the level of a constitutional violation.
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