Goodman & United States v. Georgia

The Bazelon Center's Statement on the Supreme Court's decision in Goodman The Supreme Court's Decision in Goodman The 11th Circuit’s decision in Goodman Goodman’s petition to the Supreme Court The brief by the United States on how Lane affects Goodman’s case

The United States Supreme Court decided on January 10, 2006 that the Americans with Disabilities Act protects people held in a state prison from discrimination by prison officials.

• Summary of the Case
• What's at Stake
• Briefs
• The Decision

The Case

Tony Goodman is an inmate with paraplegia who uses a wheelchair for mobility. He alleged that he was held in the Georgia State Prison for more than 23 hours a day in a cell that is so narrow (12 by 3 feet) he could not turn his wheelchair. Further, he claimed the state prison failed to make toilet and bathing facilities accessible to him, to the extent that he was sometimes forced to sit in his own waste, denied him needed medical care (such as catheters, treatment for bedsores and access to mental health counselors) and excluded him from programs and activities (such as classes and religious services) because of his disability.

Goodman filed his suit pro se in 1999, claiming that these actions constitute discrimination against him on the basis of his disability in violation of Title II of the ADA. The State of Georgia asserted sovereign immunity. The district court agreed, granting the state’s motion for summary judgment. Goodman then appealed to the Eleventh Circuit. The appellate court affirmed the grant of summary judgment with regard to Goodman’s claims for monetary damages under Title II of the ADA, based on the Supreme Court's decision in Board of Trustees of the University of Alabama v. Garrett that the Eleventh Amendment precludes suits against states for money damages that the based on the employment provisions (Title I) of the ADA. 120 Fed. Appx. 785, __ F.3d __ (11th Cir. Sept. 16, 2004) (unpublished decision).

The Supreme Court granted Goodman’s petition to decide whether Title II validly abrogates state sovereign immunity for suits by prisoners with disabilities challenging discrimination by state-operated prisons. The United States Department of Justice intervened on Goodman’s behalf to defend the constitutionality of the ADA.

What’s at Stake

Since the decision in Tennessee v. Lane, which narrowly held that individuals could sue states for money damages for denial of access to courthouses, federal appellate courts have been split over whether individuals can sue the state for money damages in other contexts under Title II of the ADA. A finding by the Supreme Court that Congress, in enacting the ADA, validly abrogated states’ immunity under Title II for claims relating to prisons would be extremely helpful in arguing that Congress also did so for other types of Title II claims, such as those relating to community integration and education. Depending on the court's analysis, however, an adverse decision in Goodman could call into question whether Congress had the constitutional authority to enact ADA Title II at all. The case was argued on November 9, 2005 and a unanimous decision was handed down on January 10, 2006.

The Decision

In an eight-page opinion, Justice Antonin Scalia ruled that Congress has the authority to apply the Americans with Disabilities Act (ADA) to state prisons, at least insofar as it reaches conduct that could also be challenged under the Fourteenth Amendment. 

We are encouraged that the decision gives Congress more authority than the states have argued it has in this and other cases. This decision is a victory for Tony Goodman, who had lost his ADA claims in the lower courts. Nonetheless, it remains unclear how plaintiffs in other situations will fare with claims under Title II of the ADA, which bars discrimination in public services. The justices avoided the central issue of whether Congress had the power to apply the ADA to state prisons generally.

The Briefs

The Bazelon Center has coordinated amicus briefs to the Supreme Court on Goodman’s behalf, linked through the descriptions here. (All are pdf files, requiring the free Adobe Reader.)

• Plaintiffs' Opening Brief:
  This brief, filed on behalf of Tony Goodman, gives background on the disability discrimination suffered by Mr. Goodman and argues that Title II is valid Fourteenth Amendment legislation as applied to state discrimination against inmates with disabilities.
  
  
• United States' Opening Brief:
  The brief filed by the United States argues that Title II is valid Fourteenth Amendment legislation as applied to state discrimination against inmates with disabilities.

Amicus Briefs

• History Brief:
  The brief filed by Paralyzed Veterans of America, Easter Seals, and 10 additional advocacy and professional organizations details the history of states' discrimination against people with disabilities in public services and activities.
  
  
• Prison History Brief:
  The brief filed by ADAPT, American Academy of Psychiatry and the Law, the ACLU and 16 other advocacy and professional organizations describes how states have discriminated against prisoners with disabilities.
  
  
• States Law Brief:
  The brief filed by the National Disability Rights Network (formerly the National Association of Protection and Advocacy Systems, NAPAS) details the inadequacy of state laws to address the many types of discrimination faced by people with disabilities.
  
  
• ABA Brief:
  The brief filed by the American Bar Association discusses the treatment of inmates in state prisons as an integral part of the administration of justice and the harm to the system of justice caused by discrimination against prisoners with disabilities.
  
  
• Thornburgh/NOD Brief:
  The brief filed by Dick Thornburgh, United States Attorney General during passage of the ADA, and the National Organization on Disabilities argues that Title II of the ADA in its entirety constitutes a proper exercise of Congress' Fourteenth Amendment authority.
  
  
• Brief by Former President Bush:
  The brief filed by former President George H.W. Bush describes the enactment of the ADA and argues that Congress properly exercised its Fourteenth Amendment powers in passing the ADA.
  
  
• Lawyer's Committee Brief:
  This brief filed by the Lawyer's Committee for Civil Rights Under Law, National Asian Pacific Foundation Legal Consortium, People for the American Way Foundation and the National Association for the Advancement of Colored People argues that Title II of the ADA in its entirety constitutes a proper exercise of Congress’ Fourteenth Amendment authority and that the Supreme Court should abandon the congruence and proportionality standard of review recently applied to Fourteenth Amendment legislation because it unduly restricts Congress' power.
  
  
• Mental Disability Brief:
  The brief filed by the American Association on Mental Retardation, the ARC of the United States, the Bazelon Center for Mental Health Law, the National Mental Health Association, the National Association of Councils on Developmental Disabilities and the American Psychological Association describes the plight of prisoners with mental disabilities.

Opposition Briefs

• Georgia's Opposition Brief:
  The brief filed by the State of Georgia argues that Congress did not validly abrogate the states' sovereign immunity in Title II for suits brought by state prison inmates for disability discrimination. See also the addendum.

• States' Brief Supporting Georgia:
  This amicus brief filed by 11 states and Puerto Rico argues that Congress exceeded its authority under the Fourteenth Amendment by abrogating states' sovereign immunity for claims brought under Title II in the context of prison administration.