Goodman v. Georgia

Brief Filed: 7/05
Court: Supreme Court of the United States
Year of Decision: 2006

Read the full-text amicus brief (PDF, 239KB)

Issue

The narrow issue before the Court is the extent to which the Americans with Disabilities Act validly abrogated state sovereignty as it applies to state prisons

Index Topic

Disabilities/Rights under the ADA

Facts

At issue in the case is whether the Americans with Disabilities Act (ADA) applies to conditions under which the disabled are held in state prisons. The 11th Amendment to the Constitution prohibits the federal government from impinging on the states’ autonomy except as otherwise authorized in the Constitution. The narrow issue before the Court is the extent to which the ADA validly abrogated state sovereignty as it applies to state prisons.

The plaintiff, Goodman, is an inmate with paraplegia who uses a wheelchair for mobility. As far as the record reveals, he does not have a history of mental illness. Goodman filed a complaint alleging that he was not accommodated in very basic ways (i.e., confined to a small cell for 23-24 hours each day and could not turn around in his wheelchair, did not have accommodation in going to the bathroom, showering, eating, etc.) and that he has been excluded from counseling, classes and religious services because of his disability. Goodman claims 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 contends that plaintiff's claims are barred by the 11th Amendment to the Constitution, arguing that Congress exceeded its authority in removing 11th Amendment immunity from the states for suits in federal courts to enforce Title II of the ADA in the context of conditions for disabled inmates in state prisons. The United States Court of Appeals for the Eleventh Circuit agreed with the State of Georgia, and plaintiff appealed to the U.S. Supreme Court.

APA's Position

APA joined the American Association on Mental Retardation, the ARC of the United States, the Bazelton Center for Mental Health Law and other amici in filing a brief which focuses on prisoners with mental illness and mental retardation. Amici states that while the petitioner’s individual claim involves a physical disability, the Court’s ruling will have a major impact on inmates with mental disabilities. The brief describes the history as well as types of discrimination that individuals with mental disabilities face in state prison, including lack of access to adequate mental health care, exclusion from prison programs, and the imposition of more severe punishment on them than on other inmates. It addresses the status of such prisoners and the ADA violations to which they may be subjected (including failure of prison authorities to provide appropriate clinical treatment and habilitation). Also discussed is the extent to which inmates can benefit from accommodation of mental disabilities and how failure to provide such accommodations imperils the safety of guards and fellow prisoners even as it does potentially irreparable harm to the health and safety of the inmate who has the disability.

Results

A unanimous decision was issued on Jan. 10, 2006. The Court ruled that Congress has the authority to apply the ADA to state prisons, at least insofar as it reaches conduct that could also be challenged under the Fourteenth Amendment. The justices avoided the central issue of whether Congress has the power to apply the ADA to state prisons generally.