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Constitutional Law Keyed to Stone
Board of Trustees of Univ. of Ala. v. Garrett
Citation:
531 U.S. 356 (2001)Facts
Patricia Garrett worked as the Director of Nursing for the University of Alabama in Birmingham Hospital. In 1994, she was diagnosed with breast cancer and underwent treatment that required substantial leave from work. Upon returning in July 1995, her supervisor informed her that she would have to give up her Director position. She was transferred to a lower-paying position as a nurse manager. Milton Ash was employed as a security officer for the Alabama Department of Youth Services. He informed his employer that he suffered from chronic asthma and sleep apnea, requesting accommodations to minimize his exposure to carbon monoxide and cigarette smoke, and requesting reassignment to daytime shifts. The Department granted none of his requested accommodations. After filing a discrimination claim with the EEOC, Ash noticed his performance evaluations were lower than previous ones. Both Garrett and Ash filed separate lawsuits seeking money damages under Title I of the ADA. The state defendants claimed Eleventh Amendment immunity from such suits. The Supreme Court had to determine whether Congress had validly abrogated states’ sovereign immunity when it enacted the ADA, which required examining whether the ADA was appropriate Section 5 legislation targeting a pattern of unconstitutional state discrimination against persons with disabilities.
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