Code Internal Revenue Service Joint Comm. However, the ruling does not extend to lawsuits against local government employers. Facts of the Case Patricia Garrett sued the University of Alabama at Birmingham in federal district court for demoting her due to her breast cancer.
Benefits are one of the terms and conditions of employment.
Garrett's case was consolidated for appeal with the ADA claim of Milton Ash, who sued the Alabama Department of Youth Services for failing to accommodate his asthma. The district court ruled that the claims could not be brought against Alabama in federal court because of the 11th Amendment to the U.S. Constitution, which grants states immunity from such suits. The appeals court reversed, determining that Congress validly nullified that immunity in the ADA by exercising its power under the 14th Amendment, which requires states to give equal protection of the laws to all persons and permits the federal government to force the states to do so. Alabama appealed this ruling. In a 5-4 decision, the Supreme Court ruled that Title I did not remedy every pattern of unconstitutional discrimination by the states.