United States v. Georgia, 546 U.S. 151 (2006)
Primary Holding
Disabled inmates may sue state governments for money damages under Title II of the Americans with Disabilities Act (ADA), as Congress has abrogated state sovereign immunity in this context.
In the case of United States v. Georgia, the Supreme Court decided that disabled inmates can sue state governments for money if they face discrimination in prisons. This is important because it means that people with disabilities have the right to seek compensation when their rights under the Americans with Disabilities Act (ADA) are violated, even when the state tries to claim immunity. This case is relevant for anyone with a disability who feels they have been treated unfairly in a state prison, as it gives them a way to hold the state accountable.
AI-generated plain-language summary to help you understand this case
A paraplegic in a Georgia state prison, Tony Goodman, brought an action against the state on the grounds that prison authorities discriminated against disabled individuals in violation of Title II of the ADA. Citing the Eleventh Amendment, Georgia asserted the principle of state sovereign immunity and prevailed in the trial court. The Eleventh Circuit reversed the decision after the federal government sued Georgia under the theory that Title II abolished state sovereign immunity in these situations. It argued that the Fourteenth Amendment gave Congress the power to enforce equal protection in prisons.
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.
The judgment is reversed and remanded.
The Court used the Eighth Amendment to invalidate sovereign immunity in this instance, but it is less clear whether the ADA itself would justify removing state sovereign immunity.
- Court
- Supreme Court
- Decision Date
- November 9, 2005
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Scalia
- Damages Awarded
- N/A
- Data Quality
- high
Wilkinson v. Dotson, 544 U.S. 74 (2005)
Consumer WonPrisoners may bring actions under 42 U.S.C. §1983 to challenge the constitutionality of state parole procedures, rather than being required to seek relief exclusively through federal habeas corpus statutes.
Jones v. Bock, 549 U.S. 199 (2007)
Consumer WonThe Prison Litigation Reform Act (PLRA) does not require prisoners to allege and demonstrate exhaustion of administrative remedies in their complaints, nor does it permit courts to dismiss an entire action based on the failure to exhaust any single claim; such procedural rules exceed the proper limits of the judicial role.
Northern Ins. Co. of N. Y. v. Chatham County, 547 U.S. 189 (2006)
Consumer WonSovereign immunity extends to counties and municipalities, allowing them to assert immunity from suit based on the principle of state immunity, even if they do not qualify as an "arm of the State" under the Eleventh Amendment.
Allen v. Siebert, 552 U.S. 3 (2007)
Consumer LostA state postconviction petition rejected by the state court as untimely is not considered "properly filed" under 28 U.S.C. § 2244(d)(2), and thus does not toll the one-year statute of limitations for filing a federal habeas petition.