United States v. Georgia
Encyclopedia
United States v. Georgia, , was a U.S. Supreme Court case in which the court decided that the protection of Americans with Disabilities Act of 1990
(ADA), passed by the U.S. Congress, extends to persons held in a state prison and protects prison inmates from discrimination on the basis of disability
by prison personnel. Specifically, the court held that Title II of the Americans with Disabilities Act of 1990, ., is a proper use of Congressional power under the Fourteenth Amendment
, Section 5, making it applicable to prison system officials.
, sued the State of Georgia
and others alleging that the conditions of his confinement in the Georgia state prison system violated ADA. Goodman stated that, because of his disability, he was kept in his cell for twenty-three hours per day, a cell too narrow for him to move his wheelchair, and denied access to medical treatment, such as catheter
s, treatment for bed sores and boil
s and access to mental health care, and to other privileges granted to prison inmates, such as access to programs, classes, and religious activities. Further, he claimed the prison was not handicapped accessible. For example, the prison did not make toilet and bathing facilities accessible to him, such that he was occasionally forced to sit in his own human waste
. He was also injured multiple times while trying to transfer from his wheelchair to the shower or toilet himself, as assistance in these matters was denied.
The position of Georgia was that state prisons were immune from suit for damages, claiming that the U.S. Congress had exceeded its constitutional authority in authorizing suits for damages against states under ADA.
Americans with Disabilities Act of 1990
The Americans with Disabilities Act of 1990 is a law that was enacted by the U.S. Congress in 1990. It was signed into law on July 26, 1990, by President George H. W. Bush, and later amended with changes effective January 1, 2009....
(ADA), passed by the U.S. Congress, extends to persons held in a state prison and protects prison inmates from discrimination on the basis of disability
Disability
A disability may be physical, cognitive, mental, sensory, emotional, developmental or some combination of these.Many people would rather be referred to as a person with a disability instead of handicapped...
by prison personnel. Specifically, the court held that Title II of the Americans with Disabilities Act of 1990, ., is a proper use of Congressional power under the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
, Section 5, making it applicable to prison system officials.
Facts of the case
The petitioner, Tony Goodman, a paraplegic prisoner using a wheelchairWheelchair
A wheelchair is a chair with wheels, designed to be a replacement for walking. The device comes in variations where it is propelled by motors or by the seated occupant turning the rear wheels by hand. Often there are handles behind the seat for someone else to do the pushing...
, sued the State of Georgia
Georgia (U.S. state)
Georgia is a state located in the southeastern United States. It was established in 1732, the last of the original Thirteen Colonies. The state is named after King George II of Great Britain. Georgia was the fourth state to ratify the United States Constitution, on January 2, 1788...
and others alleging that the conditions of his confinement in the Georgia state prison system violated ADA. Goodman stated that, because of his disability, he was kept in his cell for twenty-three hours per day, a cell too narrow for him to move his wheelchair, and denied access to medical treatment, such as catheter
Catheter
In medicine, a catheter is a tube that can be inserted into a body cavity, duct, or vessel. Catheters thereby allow drainage, administration of fluids or gases, or access by surgical instruments. The process of inserting a catheter is catheterization...
s, treatment for bed sores and boil
Boil
A boil, also called a furuncle, is a deep folliculitis, infection of the hair follicle. It is always caused by infection by the bacterium Staphylococcus aureus, resulting in a painful swollen area on the skin caused by an accumulation of pus and dead tissue...
s and access to mental health care, and to other privileges granted to prison inmates, such as access to programs, classes, and religious activities. Further, he claimed the prison was not handicapped accessible. For example, the prison did not make toilet and bathing facilities accessible to him, such that he was occasionally forced to sit in his own human waste
Human waste
Human waste is a waste type usually used to refer to byproducts of digestion, such as feces and urine. Human waste is most often transported as sewage in waste water through sewerage systems...
. He was also injured multiple times while trying to transfer from his wheelchair to the shower or toilet himself, as assistance in these matters was denied.
The position of Georgia was that state prisons were immune from suit for damages, claiming that the U.S. Congress had exceeded its constitutional authority in authorizing suits for damages against states under ADA.