States are not required by the 14th Amendment to make special accommodations for the disabled, so long as their actions towards such individuals are rational.
Garrett and Ash (appellants) were both partially disabled state employees who requested the ADA for reasonable accommodation, but were refused. They sued to recover money damages for petitioner state agency's failure to comply with Title I of the Americans with Disabilities Act. The lower court had held that the Americans with Disabilities Act validly abrogated the States' immunity under the 11th Amendment. Relying on its prior equal protection precedent, the court concluded that states were not required by the 14th Amendment to make special accommodations for the disabled, so long as their actions towards such individuals had a rational basis. Thus, if special accommodations for the disabled were to be required, they would have had to come from positive law and not through the Equal Protection Clause. Congress had not identified a history and pattern of unconstitutional employment discrimination by the states against the disabled because its general findings and the anecdotal incidents in the ADA's legislative history fell short of suggesting a pattern of unconstitutional discrimination on which 14th Amendment legislation was required to be based. Even if a pattern of discrimination were shown, however, the rights and remedies in the ADA were not congruent and proportional to the targeted violation given the ADA's sweeping requirements. Appellant's petition for writ of certiorari to the United States Court of Appeals for the Eleventh Circuit was granted.
Did the Americans with Disabilities Act, in subjecting states to suits by private parties (state employees) for money damages in a federal court, exceed Congress' authority to abrogate the states' immunity from such suits under the 11th Amendment?
The judgment of the lower court was reversed because Congress had not identified a history and pattern of unconstitutional employment discrimination against the disabled by states sufficient to abrogate States' 11th Amendment immunity. Congress is the final authority as to desirable public policy, but in order to authorize private individuals to recover money damages against the states, there must be a pattern of discrimination by the states which violates the 14th Amendment, and the remedy imposed by Congress must be congruent and proportional to the targeted violation. Those requirements were not met in this case. Accordingly, the court held that suits by state employees to recover money damages by reason of the State's failure to comply with the provisions of Title I of the Americans with Disabilities Act are barred by the 11th Amendment, and the judgment of the lower court was REVERSED.