Happy 25th Birthday Olmstead v. L.C.: The Supreme Court, the ADA, and persons with disabilities

On June 22, 1999. the U.S. Supreme Court announced the 6 to 3 ruling in Olmstead v. L.C. In this case, the Supreme Court ruled on the integration mandate of the Americans with Disabilities Act (ADA). In the majority opinion, Justice Ruth Baker Ginsburg wrote that the unjustified segregation of people with disabilities is a form of discrimination that violates the ADA. Persons with disabilities, therefore, have a right under the ADA to receive state-funded community services rather than being warehoused in institutions.

The case involved Lois Curtis (L.C.) and Elaine Wilson (E.W.), two women with intellectual disabilities and psychiatric disorders who had spent the majority of their adult lives after being voluntarily committed to the Georgia Regional Hospital. After their courses of treatment, the hospital’s mental health professionals determined that the women were ready to be moved to a community-based program. However, both women remained confined to the institution. L.C. was approached by a young attorney from the Atlanta Legal Aid Society, Sue Jamieson, who offered to help her. Jamieson recalled that LC asked her repeatedly to “Please get me out of here” (Olmstead Rights, 2014).

Ms. Jamieson took the case to the legal director of the Atlanta Legal Aid Society, Steve Caley, who helped L.C., who was 27 years old, bring the case to the U.S. District Court for the Northern District of Georgia. At this time E.W. was added to the case. Ms. Jamieson and Mr. Caley argued that the State’s failure to place L.C. and E.W. in the community-based facility violated Title II of the ADA. The federal district court ruled in favor of L.C. and E.W. The State of Georgia appealed to the U.S. Court of Appeals for the 11th Circuit, which affirmed the lower court’s ruling. The attorney general of Georgia filed an appeal with the U.S. Supreme Court, which granted certiorari and the case was argued on April 21, 1999, and decided on June 22, 1999.

According to Justice Ginsburg, the ruling was based on two primary issues. First, continued institutional placements of persons with disabilities who can handle and benefit from community-based settings perpetuates unwarranted assumptions that persons that isolated in such a way are incapable or unworthy of participating in community life. Second, confinement in an institution severely diminished the everyday life activities of such individuals, including family relations, social contacts, work options, economic independence, educational advancement, and cultural enrichment. The High Court concluded that “under Title II of the ADA states are required to provide community-based treatment for persons with mental disabilities when the State’s treatment professional determine that such placement is appropriate, the affected persons do not oppose such treatment, and the placement can be reasonably accommodated, taking into account the resources available to the state and the needs of others with mental disabilities” (Olmstead, 1999, p. 607).

Olmstead v. L.C. has been called the Brown v. Board (1954) for people with disabilities because the ruling is one of the most important civil rights decisions for people with disabilities since the 1954 ruling. The Civil Rights Division of the U.S. Department of Justice has made enforcement of Olmstead a priority.

For a fascinating look at this decision, which includes interviews with Sue Jamieson and Steve Caley and an in-depth investigation conducted by the Atlanta Journal-Constitution of Georgia’s follow-up to the Olmstead ruling, see “Olmstead: From the Case Toward Real Transformation.”

On Oyez.com you can listen to the oral arguments before the Supreme Court in Olmstead v. L.C.

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