In this case, the Supreme Court ruled in 1999 that Americans with Disabilities Act's ban on disability discrimination forbids the unnecessary institutionalization of people with disabilities. This has been an enormously important holding, spawning masses of litigation, much of it seeking to substitute community care for institutionalization for people with intellectual disabilities and mental illness. The case has been called the "Brown v. Board of Education" of people with disabilities, because of its call for integration not segregation.
The underlying lawsuit began in May 11, 1995, when a developmentally disabled woman filed a complaint against various Georgia state officials under 42 U.S.C. §1983, ADA §§12131-12134 and Due Process Clause in the U.S. District Court for the Northern District of Georgia, Atlanta Division. The plaintiff, represented by public services counsel, asked the Court for declaratory and injunctive relief, alleging that despite the professional judgment of her psychiatric treatment team, she no longer required in-patient psychiatric treated but instead needed community-based services, defendants had continued to confined at Georgia Regional Hospital (GRH). Specially, she alleged that her continued unnecessary confinement violated her rights to freedom from undue restraint, minimally adequate treatment, freedom from illegal discrimination, and placement in the most integrated setting appropriate to her needs. An additional plaintiff was permitted to interven in January 29, 1996; this plaintiff, a 43-year-old developmentally disabled woman, alleged that she was confined unnecessarily and inappropriately at GRH and sought release into a community-based program.
On March 26, 1997, the Court (Judge Shoob) granted partial summary judgment in favor of the plaintiffs. The Court held that the State's failure to place the plaintiffs in a community-based treatment program violated Title II of ADA. In so ruling, the court rejected the State's argument that inadequate funding, not discrimination, accounted for their retention at GRH.
The defendants appealed. On April 8, 1998, the 11th Circuit affirmed the District Court's judgment, but remanded for reassessment of the State's cost-based defense. The appellate court asked the district court to consider, among other things, whether the additional expenditures necessary to treat the plaintiffs in community-based care would be unreasonable given the demands of the State's mental health budget.
The defendants were not satisfied and sought and obtained review by the Supreme Court. On June 22, 1999, the Supreme Court (Justice Ginsburg) affirmed the decision of the 11th Circuit in substantial part, and remanded the case for further consideration of the appropriate relief. The Supreme Court held that unjustified segregation in institutions is discrimination not only because it perpetuates unwarranted assumptions that people with disabilities are incapable or unworthy of participating in community life, but also because confinement in an institution severely curtails everyday life activities, such as family relations, social contacts, work, educational advancement and cultural enrichment.
Under Title II of the Americans with Disabilities Act, said Justice Ruth Bader Ginsburg, delivering the opinion of the court, "states are required to place persons with mental disabilities in community settings rather than in institutions when the State's treatment professionals have determined that community placement is appropriate, the transfer from institutional care to a less restrictive setting is not opposed by the affected individual, and the placement can be reasonably accommodated, taking into account the resources available to the State and the needs of others with mental disabilities. "
Nonetheless, the Supreme Court held, the states' need to maintain a range of facilities for the care and treatment of individuals with diverse mental disabilities must be recognized. However, The Supreme Court held that the Eleventh Circuit's remand instruction to consider the cost of providing the litigants with community based services in light of the state's mental health budget was unduly restrictive. In evaluating a state's fundamental alteration defense, courts must consider not only the cost of providing community based care to the litigants, but also the range of services the state provides to others with mental disabilities and its obligation to mete out those services in an equitable manner. If the state shows that immediate relief for the plaintiffs would be inequitable "given the responsibility the state has undertaken for the care and treatment of a large and diverse population of persons with mental disabilities," it will have met the fundamental alteration defense.
On July 11, 2000, the parties reached a settlement and the Court (Judge Shoob) approved the settlement. No details on it are available.
Kunyi Zhang - 02/11/2011
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