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Board of Trustees of the University of Alabama v. Garrett

Citation. 531 U.S. 356, 121 S.Ct. 955, 148 L.Ed.2d 866 (2001).

Brief Fact Summary.

Plaintiffs were denied accommodations for their documented disabilities by their employers and filed suit under the ADA.

Synopsis of Rule of Law.

The ADA provision requiring reasonable accommodations for disabled workers is unconstitutional when applied to state workers.


Plaintiffs were both employees of the state of Alabama, a registered nurse and security guard. Both were refused reasonable accommodations and were transferred to different jobs with less pay because of their disabilities. Plaintiffs filed separate suits, both arguing Defendant had violated their rights under the ADA.


Whether the ADA provision requiring mandatory reasonable accommodations for workers with disabilities is constitutional when applied to state workers.


No. The ADA provision requiring mandatory reasonable accommodations for workers with disabilities is not constitutional when applied to state workers.


Justice Breyer

Congress could have reasonably concluded that the remedy provided here is an appropriate way to enforce basic equal protection requirements. That is all the Constitution requires. This decision also does nothing to protect the federalism requirement under the Constitution.


Rational basis applies. The 14th Amendment does not require states to make special provisions to employ the disabled. They must only act in a reasonable matter. Congress has only made a general finding in the ADA that society has tended to isolate and segregate individuals with disabilities. Such a finding, however, far exceeds what is constitutionally required because the rights and remedies afforded are not congruent to the wrong or proportional to the magnitude. Judgement reversed.

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