## Facts

- Patricia Garrett, a director of nursing employed by a state university hospital, took substantial leave for breast cancer treatment and alleged that, upon returning, she was required to relinquish her position.
- Milton Ash, a state security officer with severe asthma, requested workplace modifications to reduce exposure to asthma triggers; he alleged the requests were denied and his evaluations declined.
- Garrett and Ash sued Alabama state employers in federal court seeking money damages under Title I of the Americans with Disabilities Act of 1990 (ADA), which bars disability discrimination in employment.
- The state employers moved to dismiss on the ground that the Eleventh Amendment bars private damages actions against nonconsenting states.
- The district court ruled for the state employers; the Eleventh Circuit reversed; the Supreme Court granted review.

## Issues

1. Whether Congress validly exercised its Fourteenth Amendment § 5 enforcement power to abrogate state sovereign immunity for private suits seeking money damages under Title I of the ADA.
2. Whether Title I, as applied to state employers, satisfies the § 5 requirement that enforcement legislation be congruent and proportional to a pattern of unconstitutional state conduct.

## Decision

- The Supreme Court reversed the Eleventh Circuit and held that the Eleventh Amendment bars federal-court suits by state employees seeking money damages for a state’s failure to comply with Title I of the ADA.
- Congress unmistakably expressed an intent to abrogate state immunity in the ADA, but Title I was not a valid exercise of Congress’s § 5 power as applied to the states.
- The Court reasoned that disability classifications receive rational-basis review under the Equal Protection Clause and that the legislative record did not establish a sufficient pattern of unconstitutional (irrational) state employment discrimination.
- The Court further concluded that Title I’s accommodation-focused obligations impose affirmative requirements that extend beyond what the Fourteenth Amendment itself requires, making the remedy insufficiently tailored to documented constitutional violations.
- The ruling did not foreclose prospective injunctive relief against state officials in their official capacities.

## Legal Principles

- Congress may abrogate Eleventh Amendment immunity only when it clearly states that intent and acts pursuant to a valid grant of constitutional authority.
- Under Fourteenth Amendment § 5, Congress may enact enforcement legislation, but it may not expand the substantive meaning of the Fourteenth Amendment beyond judicial interpretations.
- § 5 legislation must show congruence and proportionality between the constitutional injury to be prevented or remedied and the statutory means adopted.
- Disability-based classifications by states are generally subject to rational-basis review; absent irrational treatment, the Equal Protection Clause does not require special accommodations.

## Conclusion

Title I of the ADA does not validly abrogate state sovereign immunity under § 5 of the Fourteenth Amendment for private suits seeking money damages, so nonconsenting states are immune from such claims in federal court, although certain forward-looking relief against state officials may remain available.


Bd. of Trs. of Univ. of Ala. v. Garrett, 531 U.S. 356 (2001)