Law School Case Brief
Bd. of Trs. v. Garrett - 531 U.S. 356, 121 S. Ct. 955 (2001)
The Americans with Disabilities Act (ADA) prohibits certain employers, including the states, from discriminating against a qualified individual with a disability because of the disability of such individual in regard to job application procedures, the hiring, advancement, or discharge of employees, employee compensation, job training, and other terms, conditions, and privileges of employment. To this end, the ADA requires employers to make reasonable accommodations to the known physical or mental limitations of an otherwise qualified individual with a disability who is an applicant or employee, unless the employer can demonstrate that the accommodation would impose an undue hardship on the operation of the employer's business.
State employees filed separate suits seeking monetary damages from the state under provisions including Title I of the Americans with Disabilities Act (ADA) (42 U.S.C.S. §§ 12111 et seq.), which prohibits employment discrimination by states and other employers against a qualified individual with a disability on the basis of that disability. The district court granted the state's motions for summary judgment on the ground that the ADA, in subjecting states to suits by private parties for money damages in a federal court, exceeded Congress' authority to abrogate the states' immunity from such suits under Eleventh Amendment.
Does the Eleventh Amendment protect the state from the claims of state employees under the American with Disabilities Act?
Suits in federal court by state employees to recover money damages by reason of the State's failure to comply with Title I of the ADA are barred by the Eleventh Amendment. Judgment of the lower court was reversed because Congress had not identified history and pattern of unconstitutional employment discrimination against disabled by states sufficient to abrogate the States' Eleventh Amendment immunity.
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