Narrative Opinion Summary
The case is on remand from the U.S. Supreme Court concerning whether two Alabama state agencies have sovereign immunity against claims under the Americans with Disabilities Act (ADA). The district court previously ruled in favor of the agencies, granting summary judgment based on the precedent set in Kimel v. State Bd. of Regents, which stated that states are not immune from ADA suits. However, the Supreme Court reversed this decision in Board of Trustees of the University of Alabama v. Garrett, holding that state employees cannot sue for money damages under the ADA due to Eleventh Amendment protections. The Supreme Court's ruling also applies to the Rehabilitation Act, leading to the affirmation of the district court's judgment for both the ADA and Rehabilitation Act claims.
Legal Issues Addressed
Application of Supreme Court Precedent to ADA Claimssubscribe to see similar legal issues
Application: The district court originally relied on Kimel v. State Bd. of Regents, but this precedent was abrogated by the Supreme Court’s later decision in Garrett.
Reasoning: The district court previously ruled in favor of the agencies, granting summary judgment based on the precedent set in Kimel v. State Bd. of Regents, which stated that states are not immune from ADA suits. However, the Supreme Court reversed this decision in Board of Trustees of the University of Alabama v. Garrett, holding that state employees cannot sue for money damages under the ADA due to Eleventh Amendment protections.
Extension of Eleventh Amendment Immunity to Rehabilitation Act Claimssubscribe to see similar legal issues
Application: The Supreme Court’s reasoning regarding sovereign immunity under the ADA was also applied to claims brought under the Rehabilitation Act.
Reasoning: The Supreme Court's ruling also applies to the Rehabilitation Act, leading to the affirmation of the district court's judgment for both the ADA and Rehabilitation Act claims.
Sovereign Immunity of State Agencies under the Americans with Disabilities Act (ADA)subscribe to see similar legal issues
Application: The court held that Alabama state agencies are protected by sovereign immunity and cannot be sued for money damages under the ADA.
Reasoning: The Supreme Court reversed this decision in Board of Trustees of the University of Alabama v. Garrett, holding that state employees cannot sue for money damages under the ADA due to Eleventh Amendment protections.