Case Citator › Martin v. State of Kansas

Martin v. State of Kansas

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
Tenth Circuit
Citation
190 F.3d 1120
Decided
Confirmed treatments
4
Flagged citations read
45 of 45
Citing cases (total)
45
Treatment dates
2000–2003
Overruled in part
A reviewed court has overruled part of this case’s holding. Martin v. State of Kansas was overruled in part on state immunity from Title I ADA damages suits. All 45 flagged citations have been read.
More on how this was screened

The Supreme Court's decision in Board of Trustees of the University of Alabama v. Garrett displaced Martin's immunity holding; the Tenth Circuit later described Martin as overruled on that ground while continuing to apply its other ADA holdings. The 4 confirmed adverse treatments are listed below.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

45 later cases cite Martin v. State of Kansas; 45 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Martin v. State of Kansas?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled in part

  • The Supreme Court held that employees cannot recover money damages from a state under Title I of the ADA, displacing Martin's contrary state immunity holding.

    Board of Trustees of the University of Alabama v. Garrett · Supreme Court of the United States · filed

    We decide here whether employees of the State of Alabama may recover money damages by reason of the State’s failure to comply with the provisions of Title I of the Americans with Disabilities Act of 1990 (ADA or Act), 104 Stat. 330, 42 U. S. C. §§ 12111-12117.1 We hold that such suits are barred by the Eleventh Amendment.
    Read the full opinion on CourtListener →

Limited

  • The Tenth Circuit held that Martin did not decide whether Title II of the ADA overcame state immunity and analyzed Title II separately.

    Thompson v. Colorado · Tenth Circuit · filed

    Thus, even if Martin was a holding as to the entire ADA, Garrett demonstrates that it was error to conduct the abrogation analysis at that level of generality.4 See Currier v. Doran, 242 F.3d 905, 912 (10th Cir.2001) (stating that a panel is not bound by a prior panel opinion when there is a superseding Supreme Court decision). Therefore, this court now writes on a clean slate in addressing whether Title II of the ADA is a valid abrogation of the states' Eleventh Amendment immunity.
    Read the full opinion on CourtListener →

Criticized

  • The Second Circuit criticized Martin's review of a general medical inquiry policy for accepting the employer's justification without enough scrutiny and appearing to shift the burden to the employee.

    Conroy v. New York State Department of Correctional Services · Second Circuit · filed

    Under the standard that we set out today, we believe that a court should examine the employer’s asserted justification more carefully than the Martin court did in order to determine whether a policy was consistent with business necessity. The Tenth Circuit appears to have shifted the burden back to the plaintiff to rebut the employer’s written policy. Despite our doubts about the outcome in Martin, we do not believe that the ADA categorically prohibits an employer from implementing a general policy requiring medical certification with general diagnoses.
    Read the full opinion on CourtListener →

Questioned

  • Before Garrett was decided, the Tenth Circuit questioned whether Martin's ADA immunity holding survived the Supreme Court's ruling in Kimel and reserved the issue.

    Johnson v. University of Oklahoma · Tenth Circuit · filed

    We have previously held that the ADA is a valid abrogation of the States’ Eleventh Amendment immunity, see Martin v. Kansas , 190 F.3d 1120, 1125-28 (10th Cir. 1999). However, since the Supreme Court decided Kimel v. Florida Board of Regents , 120 S. Ct. 631, 649-50 (2000), courts have split on the issue of whether Congress validly abrogated the States’ immunity from suit under the ADA. The Supreme Court has accepted certiorari on this issue. See University of Ala. at Birmingham Bd. of Trustees v. Garrett , 120 S. Ct. 1669 (U.S. Apr. 17, 2000) (No. 99-1240). Because we determine that Ms. Johnson cannot establish a valid claim under the ADA, we need neither address this issue nor abate this case pending the Supreme Court’s determination.
    Read the full opinion on CourtListener →

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