Association for Disabled Americans v. Florida International University

405 F.3d 954 (11th Cir. 2005) ; Clearinghouse Number: 55931

Description

Eleventh Amendment Does Not Prevent Persons with Disabilities from Suing State University Under Title II of the ADA, Says Eleventh Circuit

Abstract

The Eleventh Circuit ruled that the Eleventh Amendment did not bar plaintiffs—an organization advocating for people with disabilities and individuals with hearing impairments—from suing defendant university under Title II of the Americans with Disabilities Act (ADA) for failure to provide qualified sign language interpreters and other accommodations. The district court granted defendant’s motion to dismiss on the basis of Eleventh Amendment immunity; plaintiffs appealed, and the United States intervened to defend Title II’s abrogation of immunity. The appeal was stayed pending the U.S. Supreme Court’s decision in Tennessee v. Lane, 541 U.S. 509 (2004) (Clearinghouse No. xxxxx). Relying on City of Boerne v. Flores, 521 U.S. 507 (1997), the Eleventh Circuit noted that congressional action to remedy or prevent discrimination was valid under Section 5 of the Fourteenth Amendment if the legislation exhibited congruence and proportionality between the injury and the means adopted to prevent or remedy it. The court used a three-step analysis: determining (1) what constitutional right Congress sought to enforce, (2) whether a history of unconstitutional discrimination supported Congress’ finding that the legislation was necessary, and (3) whether Title II was an appropriate response. Applying this framework, the court said first that, under Lane, Title II sought to prohibit “irrational disability discrimination.” Although classifications relating to education should be reviewed under the rational-basis standard, the Supreme Court has consistently recognized the importance of education. Second, Lane found that Congress had documented a history of unconstitutional disability discrimination in public services. Third, Congress chose a limited remedy; Title II allows states to exclude persons from benefits for lawful reasons unconnected with disability and requires only reasonable modifications that do not fundamentally alter the nature of defendant’s programs.

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Attorney Information
Docket Date
2005-04-06 00:00:00+00:00

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