Olmstead v. L.C. (1999) was a landmark U.S. Supreme Court decision that established that unnecessary segregation of people with disabilities is a form of disability discrimination under Title II of the Americans with Disabilities Act (ADA). The case involved two women, Lois Curtis (L.C.) and Elaine Wilson (E.W.), who had intellectual disabilities and mental health conditions. They were receiving treatment in a Georgia state psychiatric hospital although their treatment professionals determined that they could be appropriately served in a community-based setting, they remained institutionalized for years because the state had not provided community placements.
The women sued the State of Georgia, arguing that unnecessary institutionalization violated the ADA. L.C. received assistance from Sue Jamieson, a young attorney with the Atlanta Legal Aid Society, who agreed to represent her. According to Jamieson, L.C. repeatedly pleaded, “Please get me out of here.” Jamieson brought the case to the organization’s legal director, Steve Caley, who helped file the lawsuit in the U.S. District Court for the Northern District of Georgia. By that time, E.W. had joined the case as a co-plaintiff. Together, Jamieson and Caley argued that Georgia’s failure to place the two women in a community-based setting, where they could work toward reintegration into society, violated Title II of the ADA. The 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 Eleventh Circuit, which upheld that decision. The Georgia attorney general then petitioned the U.S. Supreme Court for review. The Court granted certiorari, and heard oral arguments were heard on April 21, 1999.
Justice Ruth Bader Ginsburg wrote the opinion for the High Court, which ruled the action was discriminatory in a 6 to 3 decision. In her majority opinion, Justice Ginsburg noted that unjustified isolation of people with disabilities was discrimination under the ADA and that public entities must provide services in the most integrated setting appropriate to an individual’s needs when the (a) state’s treatment professionals determine that community-based services are appropriate; (b) individual does not oppose community placement; and (c) placement can be reasonably accommodated, considering the state’s available resources and the needs of others receiving disability services.
Olmstead was a very important ruling because established the “integration mandate” under the ADA, requiring public entities to avoid unnecessary segregation of individuals with disabilities whenever appropriate. The bottom line of the decision was to affirm that people with disabilities have the right to receive services in integrated settings whenever appropriate. For over 26 years the vast majority of federal courts have treated the Olmstead integration mandate as binding Supreme Court precedent and have applied it in numerous disability rights cases.
The Olmstead ruling has been called the Brown v. Board for persons with disabilities. Like Brown v. Board of Education (1954), which held that racial segregation in public schools was inherently unequal, Olmstead ruled that unnecessary segregation of people with disabilities can constitute unlawful discrimination. Although the two cases arose under different laws and addressed different forms of discrimination, both are landmark civil rights decisions that advanced the principle of equal opportunity through integration rather than segregation.
To listen to the oral arguments before the Supreme Court and read the final opinion, click here on the OYEZ website. For an interesting look at the Olmstead, see the Olmstead Rights website.
Courts later applied the Olmstead integration mandate beyond state psychiatric hospitals to a wide variety of public services for individuals with disabilities. Such public services included nursing homes, community mental health services, and Medicaid home- and community-based services
On June 18, 2026, the Trump administration’s Department of Justice’s Office of Legal Counsel issued an opinion taking the position that the ADA and Section 504 do not themselves impose an integration mandate and that Olmstead should be interpreted more narrowly. The DOJ also announced that it would no longer rely on its prior Olmstead guidance for enforcement. This opinion is binding within the Executive branch and directs how DOJ attorneys and agencies approach enforcement. However, it does not overrule the existing Supreme Court present nor does it bind the federal courts. Although the federal government’s enforcement position has shifted, Olmstead itself remains controlling law unless the Supreme Court overturns or limits its own decision.
Interested readers may find articles on the recent DOJ opinion in Disability Scoop, PBS, and Politico.
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