Introduction

The case of School Board of Nassau County, Florida, et al. v. Arline, 480 U.S. 273 (1987), serves as a pivotal moment in the interpretation of federal disability law. This landmark judgment addressed whether individuals afflicted with contagious diseases fall under the definition of "handicapped individuals" as per §504 of the Rehabilitation Act of 1973. The Supreme Court's decision in this case has far-reaching implications for employment discrimination, particularly in contexts where the health and safety of others are at stake.

Gene Arline, a teacher in Nassau County, Florida, was dismissed from her position after experiencing multiple relapses of tuberculosis, a contagious disease. Arline contended that her termination constituted discrimination based on disability under §504, leading to a legal battle that ultimately reached the highest court in the United States.

Summary of the Judgment

The Supreme Court held that an individual with a contagious disease, such as tuberculosis, may indeed be considered a "handicapped individual" under §504 of the Rehabilitation Act. The Court emphasized that the presence of a physical impairment, which substantially limits major life activities, coupled with the contagious nature of the disease did not exclude the individual from protection under the Act. Instead, it necessitated a nuanced, individualized inquiry to determine whether the person was "otherwise qualified" for their position.

The Court affirmed the decision of the Court of Appeals, which had recognized that persons with contagious diseases are within the scope of §504. However, it remanded the case for further factual findings to ascertain whether Arline was indeed "otherwise qualified" for her teaching role, considering the potential health risks to students and the possibility of reasonable accommodations.

Analysis

Precedents Cited

The Court's decision in Arline drew upon several key precedents to shape its interpretation of §504:

• SOUTHEASTERN COMMUNITY COLLEGE v. DAVIS, 442 U.S. 397 (1979): Established the definition of an "otherwise qualified" individual, focusing on the ability to perform essential job functions with or without reasonable accommodations.
• CONSOLIDATED RAIL CORPORATION v. DARRONE, 465 U.S. 624 (1984): Highlighted the significance of Department of Health and Human Services (HHS) regulations in interpreting statutory definitions.
• Pennhurst State School and Hospital v. Halderman, 451 U.S. 1 (1981): Emphasized that conditions tied to federal financial assistance must be unambiguous.
• ALEXANDER v. CHOATE, 469 U.S. 287 (1985): Addressed the balance between achieving statutory objectives and maintaining manageable bounds for federal programs.

These cases collectively informed the Court's approach to statutory interpretation, particularly the reliance on legislative intent, regulatory definitions, and the necessity for clear congressional directives when imposing conditions on federal funding.

Legal Reasoning

The Court's legal reasoning centered on a thorough interpretation of §504, its definitions, and the accompanying HHS regulations. The key points of reasoning included:

• Definition of "Handicapped Individual": The individual must have a physical or mental impairment that substantially limits one or more major life activities, has a record of such an impairment, or is regarded as having such an impairment.
• Contagiousness and Disability: The Court reasoned that being contagious does not negate the presence of a disability. Instead, it must be evaluated whether the impairment itself, along with its potential impact on others, affects the individual's ability to perform their job.
• Legislative Intent: Congressional history indicated a concern not only for the individual's abilities but also for the discriminatory effects of others' prejudices and misunderstandings.
• Reasonable Accommodation: The Court underscored the obligation of employers to consider reasonable accommodations, provided they do not impose undue burdens.

The Court rejected the argument that contagiousness alone should exclude individuals from protections under §504, emphasizing that discrimination based on prejudices or unfounded fears is precisely what the Act aims to prevent.

Impact

This judgment has significant implications for future cases and the broader legal landscape concerning disability discrimination:

• Expanded Protections: Individuals with contagious diseases are now explicitly recognized as having potential protections under federal disability laws, provided their condition meets the statutory definitions.
• Individualized Assessment: Employers must conduct case-by-case evaluations to determine whether an individual is "otherwise qualified," considering both the disability and any potential health risks.
• Employer Responsibilities: There is an increased emphasis on employers to make reasonable accommodations and to rely on medically sound judgments rather than stereotypes or fears.
• Legal Precedent: Future litigation involving contagious diseases and employment discrimination will reference this case as a foundational precedent in interpreting §504.

Complex Concepts Simplified

§504 of the Rehabilitation Act

§504 is a federal law that prohibits discrimination against individuals with disabilities in programs and activities that receive federal financial assistance. It ensures that disabled individuals have equal opportunities in areas such as education, employment, and access to services.

"Handicapped Individual"

Under §504, a "handicapped individual" is someone who has a physical or mental impairment that substantially limits one or more major life activities, has a record of such an impairment, or is perceived as having such an impairment. This broad definition encompasses actual disabilities, past disabilities, and those perceived by others.

"Otherwise Qualified"

An "otherwise qualified" individual is someone who, despite their disability, can perform the essential functions of a job with or without reasonable accommodation. This means that if an individual can fulfill their job responsibilities without undue difficulty, they cannot be discriminated against based solely on their disability.

Reasonable Accommodation

Reasonable accommodation refers to adjustments or modifications provided by an employer to enable a person with a disability to perform their job. This could include changes to work schedules, physical adjustments to the workplace, or providing specialized equipment.

Undue Hardship

Undue hardship refers to significant difficulty or expense imposed on an employer when providing accommodations. Factors include the nature and cost of the accommodation, the financial resources of the employer, and the impact on the operation of the business.

Conclusion

The Supreme Court's decision in School Board of Nassau County, Florida, et al. v. Arline marks a significant advancement in the protection of individuals with disabilities, particularly those with contagious diseases. By recognizing that contagiousness does not inherently exclude someone from the protections of §504, the Court reinforced the principle that discrimination based on prejudice or misinformation is unlawful.

This ruling underscores the necessity for individualized assessments in employment decisions, ensuring that judgments are based on factual, medical evidence rather than societal fears. It also places a clear responsibility on employers to consider reasonable accommodations, balancing the needs of the individual against legitimate health and safety concerns.

Overall, this judgment reinforces the broader objectives of the Rehabilitation Act, promoting an inclusive and fair environment for all individuals, regardless of their health status or the perceptions of others.