| United States v. Georgia | |
|---|---|
 | |
| Argued November 11, 2005 Decided January 10, 2006 | |
| Full case name | United States v. Georgia, et al.; Tony Goodman v. Georgia, et al. |
| Docket no. | 04-1203 |
| Citations | 546U.S.151 (more) 126 S. Ct. 877; 163L. Ed. 2d 650 |
| Case history | |
| Prior | Goodman v. Ray, 120F. App'x 785 (11th Cir. 2004),cert. granted sub nom.,Goodman v. Georgia,544 U.S. 1031 (2005). |
| Holding | |
| TheAmericans with Disabilities Act of 1990 applies to state prisons. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Scalia, joined by a unanimous court |
| Concurrence | Stevens, joined by Ginsburg |
| Laws applied | |
United States v. Georgia, 546 U.S. 151 (2006), was aUnited States Supreme Court case in which the Court decided that the protection ofAmericans with Disabilities Act of 1990 (ADA), passed by theU.S. Congress, extends to persons held in astate prison and protects prison inmates from discrimination on the basis ofdisability by prison personnel. Specifically, the court held thatTitle II of the Americans with Disabilities Act of 1990,42 U.S.C. §§ 12131–12165., is a proper use ofCongressional power under theFourteenth Amendment, Section 5, making it applicable to prison system officials.[1]
The petitioner, Tony Goodman, aparaplegic prisoner using awheelchair, sued the State ofGeorgia and others alleging that the conditions of his confinement in the Georgia state prison system violated ADA. Goodman stated that, because of his disability, he was kept in his cell for twenty-three hours per day, a cell too narrow for him to move his wheelchair, and denied access to medical treatment, such ascatheters, treatment forbed sores andboils and access to mental health care, and to other privileges granted to prison inmates, such as access to programs, classes, and religious activities.[2] Further, he claimed the prison was nothandicapped accessible. For example, the prison did not make toilet and bathing facilities accessible to him, such that he was occasionally forced to sit in his ownhuman waste.[2][3] He was also injured multiple times while trying to transfer from his wheelchair to the shower or toilet himself, as assistance in these matters was denied.[4]
The position of Georgia was that state prisons were immune from suit for damages, claiming that theU.S. Congress had exceeded its constitutional authority in authorizing suits for damages against states under ADA.[2]
The Supreme Court was unanimous in its decision. It ruled that Congress has the authority to apply ADA to the administration of state prisons to the extent that it relates to conduct that actually violates the Fourteenth Amendment.[1] Thus Congress was granted more authority over the States in this area of disability rights.[5]