United States v. Georgia

Summary

Holding that Title II of the Americans with Disabilities Act validly abrogates state sovereign immunity at least insofar as it creates a private damages cause of action against States for conduct that actually violates the Fourteenth Amendment, the Court reversed the Eleventh Circuit's categorical bar on paraplegic inmate Tony Goodman's Title II money-damages claims against Georgia. Because Goodman's allegations of deliberate refusal to accommodate his disability-related needs plausibly described Eighth Amendment violations incorporated against the States through the Fourteenth Amendment's Due Process Clause, and the same conduct plausibly violated Title II, his claims could not be dismissed wholesale. The Court remanded for the lower courts to determine, claim by claim, which conduct violated Title II, to what extent it also violated the Fourteenth Amendment, and whether abrogation extends to Title II violations unaccompanied by constitutional violations. Justice Stevens, joined by Justice Ginsburg, concurred, emphasizing that constitutional rights beyond the Eighth Amendment form a 'constellation' relevant to the congruence-and-proportionality inquiry and that the outer limits of abrogation should await a fuller record.