United States v. Georgia & Goodman v. Georgia
Goodman, a paraplegic prisoner in the Georgia state prison system, sued the State of Georgia in federal court for violating Title II of the Americans with Disabilities Act (ADA). Goodman claimed that he was kept in his cell for twenty-three hours per day as a result of his disability, denied access to medical treatment and privileges provided to other inmates, and the prison was not handicapped accessible. Goodman was transferred to another prison after he filed suit.
Georgia filed a motion for summary judgment, claiming that it was immune from law suits for monetary damages on the basis of Eleventh Amendment sovereign immunity, and that Goodman’s claims for injunctive relief were rendered moot after he was transferred to another prison. The district court ruled in favor of Georgia. The Eleventh Circuit Court of Appeals upheld the district court’s holding with respect to the monetary claims, but reversed on the claims for injunctive relief, stating that injunctive relief is appropriate for violations of the ADA that are capable of being repeated.
While the case was pending in the court of appeals, the United States intervened by filing a law suit against Georgia. The United States argued that Title II of the ADA was passed under Section 5 of the Fourteenth Amendment and was intended to abolish state sovereign immunity from monetary claims. The Eleventh Circuit rejected this argument.
Questions Presented:
Goodman v. Georgia
Whether, and to what extent, Title II of the Americans with Disabilities Act of 1990, 42 U.S.C. ยง 12131 et seq., validly abrogates state sovereign immunity for suits by prisoners with
disabilities challenging discrimination by state-operated prisons, a question on which the courts of appeals are in conflict.
United States v. Georgia
Whether Title II of the Americans with Disabilities Act of 1990, 42 U.S.C. 12131 to 12165, is a proper exercise of Congress's power under Section 5 of the Fourteenth Amendment, as applied to the
administration of prison systems.
