546 U.S. 151, 126 S. Ct. 877, 163 L. Ed. 2d 650 (2006)
Tony Goodman, a paraplegic inmate in the Georgia prison system, was housed at the Georgia State Prison in Reidsville at all relevant times.1 After submitting numerous administrative grievances in the state prison system, he filed a pro se complaint in the United States District Court for the Southern District of Georgia.2 He named as defendants the State of Georgia and the Georgia Department of Corrections along with several individual prison officials.3 Goodman asserted claims under 42 U.S.C. § 1983, Title II of the Americans with Disabilities Act of 1990, and other provisions.4
He sought both injunctive relief and money damages against all defendants.5 Goodman’s pro se complaint and subsequent filings alleged that he was confined for twenty-three to twenty-four hours per day in a twelve-by-three-foot cell in which he could not turn his wheelchair around.6 The lack of accessible facilities rendered him unable to use the toilet and shower without assistance that was often denied.7 On multiple occasions he injured himself attempting transfers or was forced to sit in his own feces and urine while officials refused to assist.8 He also claimed denial of physical therapy, medical treatment, and access to virtually all prison programs and services on account of his disability.9
The District Court dismissed the § 1983 claims against all defendants for vague and insufficient notice pleading without allowing amendment.10 It also dismissed the Title II claims against all individual defendants.11 After the Supreme Court’s decision in Board of Trustees of University of Alabama v. Garrett, the District Court granted summary judgment to the state defendants on the Title II money damages claims on the ground of state sovereign immunity.12
Goodman appealed to the United States Court of Appeals for the Eleventh Circuit.13 The United States intervened to defend the constitutionality of Title II’s abrogation of state sovereign immunity.14 The Eleventh Circuit determined that Goodman had alleged facts sufficient to support a limited number of Eighth Amendment claims under § 1983 against certain individual defendants.15 It remanded to permit amendment of the complaint to develop those claims.16 It affirmed the dismissal of the Title II money damages claims against the State based on sovereign immunity under its prior decision in Miller v. King.17 The Supreme Court granted certiorari to consider whether Title II of the ADA validly abrogates state sovereign immunity with respect to the claims at issue here.18
Whether Title II of the ADA validly abrogates state sovereign immunity with respect to the claims at issue here?19
Section 5 of the Fourteenth Amendment grants Congress the power to enforce the provisions of the Amendment by creating private remedies against the States for actual violations of those provisions.20 This enforcement power includes the authority to abrogate state sovereign immunity by authorizing private suits for damages against the States.21
Yes. The Eleventh Circuit held that Goodman had alleged actual violations of the Eighth Amendment by state agents through his confinement in a cell too small for his wheelchair, denial of assistance with toileting and hygiene leading to injury and contact with waste, and deliberate indifference to his medical needs.22 Goodman asserts and the State does not dispute that this same conduct violated Title II by excluding him from participation in or denying him the benefits of prison services, programs, or activities on account of his disability.23 Because the Due Process Clause of the Fourteenth Amendment incorporates the Eighth Amendment, the conduct at issue independently violated section 1 of the Fourteenth Amendment.24
Title II validly abrogates state sovereign immunity insofar as it creates a private cause of action for damages against the States for conduct that actually violates the Fourteenth Amendment.25 The Eleventh Circuit erred in dismissing those of Goodman's Title II claims that were based on such unconstitutional conduct.26
Related opinions on this issue
Justice Stevens joined the Court's opinion but wrote separately to stress that the remand permits the parties to develop a factual record that will inform the outer limits of Title II's valid abrogation in the prison context.27 He observed that the history of mistreatment reviewed by Congress was not confined to Eighth Amendment violations.28 Other constitutional guarantees, including procedural due process and access to judicial process, apply to disabled inmates.29
Stevens noted that the lower courts must therefore examine claims for actual constitutional violations under any provision.30 They must apply the congruence and proportionality framework from City of Boerne v. Flores rather than limiting analysis to the Eighth Amendment alone.31
Whether a disabled inmate in a state prison may sue the State for money damages under Title II of the Americans with Disabilities Act of 1990?32
Yes. Goodman's pro se filings described confinement for twenty-three to twenty-four hours per day in a twelve-by-three-foot cell, repeated denial of assistance with toilet and shower use resulting in self-injury and contact with bodily waste, and denial of medical treatment and access to prison programs on account of his paraplegia.35 These facts, which the Eleventh Circuit found sufficient to state Eighth Amendment violations incorporated into the Fourteenth Amendment, also state Title II violations by excluding Goodman from prison services and activities.36 Title II therefore supplies a damages remedy against the State for this conduct.
A disabled inmate in a state prison may sue the State for money damages under Title II of the ADA when the underlying conduct actually violates the Fourteenth Amendment.37