Supreme Court Rules Prisoner Can Sue State Over Alleged ADA
By Dave Reynolds, Inclusion Daily Express
January 10, 2006
WASHINGTON, DC--People with disabilities received a partial victory Tuesday when the U.S. Supreme Court unanimously ruled that a Georgia prison inmate could use the 1990 Americans with Disabilities Act to sue the state for damages under certain circumstances.
The justices ruled, in the case of Goodman & United States v. Georgia, that states are not protected from having to pay financial damages for violating Title II of the ADA, which covers accessibility in public services, if in doing so they also violate the Fourteenth Amendment to the U.S. Constitution, which guarantees equal protection to all citizens, or the Eighth Amendment, which guarantees that prisoners be free from "cruel and unusual punishment".
The ruling means that the case will be sent back to the district court in which inmate Tony Goodman had filed his initial claims against the state.
The original suit was filed in 1999 by Goodman, 41, who has been serving time in the Georgia prison system since 1995 for aggravated assault, possession of a firearm by a convicted felon, and illegal drug possession with intent to distribute. Goodman, whose spine was severely injured in a 1992 car accident, claimed in the suit that prison officials held him at a high-security unit in a 12-foot by 3-foot cell -- much too narrow to move his wheelchair -- for 23 hours a day. He also alleged that prison staffs refused to help him transfer to the toilet, bed or shower, leaving him to sit in his own bodily wastes. His efforts to use the toilet or shower without assistance, he said, resulted in broken bones and other injuries.
Additionally, Goodman said the failure to provide accessible facilities prevented him from accessing typical prison services, such as the law library, along with recreational opportunities and educational, vocational, therapies, and counseling services.
Goodman argued that the prison violated his equal protection rights under the Fourteenth Amendment and the ADA's Title II, and claimed that he therefore is entitled to $1.2 million for mental suffering and punitive damages.
In 1998, the Supreme Court ruled that prisons are considered public programs under Title II. The issue in this case addressed whether Title II allows prisoners with disabilities to sue states for damages, and whether Congress overstepped its authority under the Fourteenth Amendment in allowing the ADA to apply to correctional facilities such as state prisons.
Attorneys for the State of Georgia argued that Goodman could not sue for damages because Congress had exceeded its power in authorizing damage suits against states under the ADA. The Eleventh Circuit Court of Appeals had thrown out Goodman's ADA claims on that basis, but the Supreme Court on Tuesday reversed that ruling.
"We are encouraged that the decision gives Congress more authority than the states have argued it has in this and other cases," wrote Ira Burnim, legal director for the Bazelon Center for Mental Health Law, in a statement Tuesday. "Today's 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 . . . The justices today avoided the central issue of whether Congress had the power to apply the ADA to state prisons generally."
"In a narrow decision that leaves many questions unanswered, the Supreme Court has 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."
In 2004, the Supreme Court narrowly ruled that states can face lawsuits from individuals if they fail to follow Title II when it comes to the courts. The justices based the ruling in Tennessee v. Lane, however, on guarantees under the Fourteenth Amendment for "equal protection under the laws" rather than the ADA.
"Limited U.S. Supreme Court Ruling Revives Disabled Inmate's Claim" (Law.com)
"Court Decides US/Goodman v. Georgia" (Disability Law Blog)
"Statement on the Supreme Courts Decision in Goodman v. Georgia" (Bazelon Center for Mental Health Law)
United States v. Georgia Et Al. (U.S. Supreme Court)