Olmstead v. Zimring Case Brief Summary | Law Case Explained

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Olmstead v. Zimring, 527 U.S. 581 (1999)

In 1990, Congress enacted the Americans with Disabilities Act, or ADA, to address pervasive exclusion and segregation of individuals with disabilities. Just 9 years later, in Olmstead versus Zimring, the Supreme Court recognized that the ADA gives individuals with disabilities a qualified right to live in community settings instead of institutions.

The State of Georgia institutionalized Lois Curtis and Elaine Wilson in a psychiatric hospital to treat their mental disabilities. When their conditions stabilized, state psychiatrists determined that treatment in a community-based program would be appropriate, and the women weren’t opposed to the idea. Despite that recommendation, Georgia kept the women institutionalized.

Consequently, Curtis and Wilson, through guardian ad litem Jonathan Zimring, sued state officials, including Tommy Olmstead. The women argued that failing to place them in community-based programs, as deemed appropriate by their psychiatrists, constituted disability discrimination under the ADA. Georgia contended that transferring the women to a community-based program would fundamentally alter the state’s mental-health services because all available funds were already expended to treat others with disabilities.

The district court rejected Georgia’s defense and granted summary judgment for the women. The Eleventh Circuit affirmed in part, finding that unjustified institutionalization is per se disability discrimination under the ADA. However, the Eleventh Circuit remanded the case for reconsideration of Georgia’s fundamental-alteration defense. It instructed the district court to allow the defense only if Georgia could show that the cost of community-based treatment for Curtis and Wilson would unreasonably burden the state’s mental-health budget. The United States Supreme Court granted cert.

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