Olmstead v. L.C.

527 U.S. 581; 119 S.Ct. 2176
Brief Filed: 3/99
Court: Supreme Court of the United States
Year of Decision: 1999

Read the full-text amicus brief (PDF, 1MB)

Issue

Whether the Americans With Disabilities Act compels a state to provide treatment for mentally disabled patients in a community placement rather than a state mental institution when that is an appropriate treatment option

Index Topics

Mentally Ill and Mentally Retarded (Rights of); Residential Treatment

Facts

Several patients in the psychiatric ward of a Georgia state hospital sued the State of Georgia alleging that they were not receiving minimally adequate treatment in violation of their rights under the Fourteenth Amendment, and that the Americans With Disabilities Act required that they be treated in the community. The State asserted that, in spite of the patients' stabilization, they remained in the state hospital due to lack of funding for community placement. The U.S. District Court for the Northern District of Georgia granted the patients' motion for summary judgment on the ADA claim at the close of discovery finding that "under the ADA, unnecessary institutional segregation of the disabled constitutes discrimination per se, which cannot be justified by a lack of funding." The United States Court of Appeals for the Eleventh Circuit affirmed, holding that the State of Georgia had a duty to provide services in a more integrated community setting when the patient's condition warranted. The court emphasized, however, that the state's duty was not absolute because accommodations under the ADA must be "reasonable." However, lack of funds could be a defense in only "the most limited of circumstances." The Eleventh Circuit remanded the case for factual findings concerning whether the state's expenditures would be so unreasonable, given the demands of the state's mental health budget, that it would fundamentally alter the service it provided. Prior to the case being remanded to the trial court, the state appealed to the U.S. Supreme Court on the issue of whether Congress intended for institutional treatment to constitute discrimination per se. The U.S. Supreme Court granted certiorari.

APA's position

APA joined with several other organizations, including the National Association of Social Workers, the American Psychiatric Nurses Association and the National Mental Health Association, and filed an amici brief arguing that: (1) when enacting the ADA, Congress intended to reverse the previous needless institutionalization and this legislative purpose is supported by the scientific literature which recognizes that, while institutional settings may be the most appropriate placement for some persons, treating other persons with mental disabilities in a deinstitutionalized, community-integrated environment yields demonstrably superior results; (2) the ADA represents the culmination of federal policy eliminating segregation and fostering community-based services for persons with disabilities; and (3) there is little risk of disruption of state programs or budgets because (a) the majority of states have already committed by statute or regulation that persons not requiring institutionalization be treated in non-institutional settings that are integrated into the communities where the persons live, and (b) some evidence shows that such treatment can be less costly than institutionalization.

Results

The U.S. Supreme Court affirmed in part and reversed in part, finding that the ADA requires states to place persons with mental disabilities in community settings when the state's treatment professionals have determined that community placement is appropriate, the transfer is not opposed by the patient, and the placement can be reasonably accommodated, taking into account the resources available to the states and the needs of others with mental disabilities.