Board of Trustees of the University of Alabama v. Garrett

In Board of Trustees of the University of Alabama v. Garrett, 531 U.S. 356, 366-68, 121 S.Ct. 955, 148 L.Ed.2d 866 (2001), the Supreme Court reaffirmed that classifications based on disability are subject only to rational basis review. The Court explained that "if the large and amorphous class of the mentally retarded were deemed quasi-suspect ..., it would be difficult to find a principled way to distinguish a variety of other groups who have perhaps immutable disabilities ... and who can claim some degree of prejudice from at least part of the public at large." Id. at 366, 121 S.Ct. 955. The Court concluded that "States are not required by the Fourteenth Amendment to make special accommodations for the disabled, so long as their actions towards such individuals are rational." Id. at 367, 121 S.Ct. 955. Concluding that Congress's action was not supported by a relevant history and pattern of constitutional violations, the Court sustained the States' Eleventh Amendment immunity to suits for damages under Title I of the Americans with Disabilities Act ("ADA"), 42 U.S.C. 12111-12117. Garrett, 531 U.S. at 374, 121 S.Ct. 955.