Date: 01-11-2006

Case Style: UNITED STATES v. GEORGIA ET AL.

Case Number: 04–1203

Judge: SCALIA

Court: United States Supreme Court on appeal from the Eleventh Circuit, Fulton County

Plaintiff's Attorney: Unknown

Defendant's Attorney: Unknown

Description:

Goodman, petitioner in No. 04–1236, is a paraplegic who sued respondent state defendants and others, challenging the conditions of his confinement in a Georgia prison under, inter alia, 42 U. S. C. §1983 and Title II of the Americans with Disability Act of 1990. As relevant here, the Federal District Court dismissed the §1983 claims because Goodman's allegations were vague, and granted respondents summary judgment on the Title II money damages claims because they were barred by state sovereign immunity. The United States, petitioner in No. 04–1203, intervened on appeal. The Eleventh Circuit affirmed the District Court's judgment as to the Title II claims, but reversed the §1983 ruling, finding that Goodman had alleged facts sufficient to support a limited number of Eighth Amendment claims against state agents and should be permitted to amend his complaint. This Court granted certiorari to decide the validity of Title II's abrogation of state sovereign immunity.

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Click the case caption above for the full text of this opinion.

Outcome: Held: Insofar as Title II creates a private cause of action for damages against States for conduct that actually violates the Fourteenth Amendment, Title II validly abrogates state sovereign immunity. Pp. 5–8.(a) Because this Court assumes that the Eleventh Circuit correctly held that Goodman had alleged actual Eighth Amendment violations for purposes of §1983, and because respondents do not dispute Good-man’s claim that this same conduct violated Title II, Goodman’s Title II money damages claims were evidently based, at least in part, on conduct that independently violated §1 of the Fourteenth Amendment the Fourteenth Amendment’s provisions by creating private remedies against the States for actual violations of those provisions. This includes the power to abrogate state sovereign immunity by authorizing private suits for damages against the States. Thus, the Eleventh Circuit erred in dismissing those of Goodman’s claims based on conduct that violated the Fourteenth Amendment. Pp. 5–7.

(b) Once Goodman’s complaint is amended, the lower courts will be best situated to determine in the first instance, on a claim-by-claim basis, (1) which aspects of the State’s alleged conduct violated Title II; (2) to what extent such misconduct also violated the Fourteenth Amendment; and (3) insofar as such conduct violated Title II but did not violate the Fourteenth Amendment, whether Congress’s purported abrogation of sovereign immunity in such contexts is nevertheless valid. Pp. 7–8. 120 Fed. Appx. 785, reversed and remanded.

Plaintiff's Experts: Unknown

Defendant's Experts: Unknown

Comments: None