## Facts

- Tony Goodman, a paraplegic inmate in the Georgia prison system, filed a pro se federal action against Georgia, its Department of Corrections, and prison officials.
- He sought relief under 42 U.S.C. § 1983 and Title II of the Americans with Disabilities Act of 1990 (ADA), including money damages under Title II.
- Goodman alleged disability-related conditions of confinement, including confinement in a cell too narrow to maneuver his wheelchair, lack of accessible toilet and bathing facilities resulting in occasional exposure to his own waste, and denial of assistance with transfers causing repeated injuries.
- He also alleged exclusion, because of his disability, from prison programs, classes, and religious activities.
- The district court dismissed the § 1983 claims as insufficiently pleaded and granted summary judgment on the Title II damages claims on Eleventh Amendment sovereign immunity grounds.
- The Eleventh Circuit affirmed dismissal of the Title II damages claims on sovereign immunity grounds but reversed in part on § 1983, holding Goodman alleged a limited set of Eighth Amendment claims.
- The United States intervened on appeal, and the Supreme Court granted certiorari to address Title II’s abrogation of state sovereign immunity in the prison context.

## Issues

1. Whether a disabled inmate may sue a State for money damages under Title II of the ADA for prison-related conduct.
2. Whether, and to what extent, Title II validly abrogates state sovereign immunity for damages actions involving state prison officials.
3. What analysis lower courts must apply where alleged conduct violates Title II, the Fourteenth Amendment, or both.

## Decision

- The Court unanimously reversed and remanded.
- It held that, insofar as Title II authorizes a private damages action against States for conduct that actually violates the Fourteenth Amendment, Title II validly abrogates state sovereign immunity.
- Because some of Goodman’s allegations were treated as stating Eighth Amendment violations (enforceable against the States through the Fourteenth Amendment) and were also alleged as Title II violations, sovereign immunity did not bar those Title II damages claims to that extent.
- The Court declined to decide categorically whether Title II validly abrogates immunity for conduct that violates Title II but does not amount to a constitutional violation.
- It directed lower courts to evaluate the complaint on a claim-by-claim basis.

## Legal Principles

- Congress may, under § 5 of the Fourteenth Amendment, create private damages remedies against States for actual violations of the Fourteenth Amendment, including by abrogating state sovereign immunity.
- Title II’s abrogation of Eleventh Amendment immunity is valid at least when the alleged Title II violation is also an actual Fourteenth Amendment violation (including incorporated Eighth Amendment protections).
- On remand, courts must determine, claim by claim: (1) whether the alleged conduct violates Title II; (2) whether it also violates the Fourteenth Amendment; and (3) for Title II-only violations, whether abrogation is valid under the congruence-and-proportionality framework.

## Conclusion

The Court held that States are not immune from Title II damages suits to the extent the challenged conduct both violates Title II and independently violates the Fourteenth Amendment, and it required lower courts to sort remaining claims through a claim-specific constitutional analysis.


United States v. Georgia, 546 U.S. 151 (2006)