Garcia v. S.U.N.Y. Health Sciences Center Of Brooklyn
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
All 64 flagged citations have been read. The Fourth and Eighth Circuits declined to follow its Rehabilitation Act immunity-waiver reasoning; the Second Circuit confined its Title II damages rule and later questioned that rule’s continuing validity; and an earlier district court also questioned it. The 5 confirmed treatments are listed below.
64 later cases cite Garcia v. S.U.N.Y. Health Sciences Center Of Brooklyn; 64 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 Garcia v. S.U.N.Y. Health Sciences Center Of Brooklyn?
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
Declined to follow
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The Eighth Circuit rejected Garcia's § 504 knowing-waiver analysis and held that Nebraska knowingly waived immunity by accepting federal funds in 1993–96 despite uncertainty about the ADA's abrogation clause.
John Doe v. State of NE · United States Court of Appeals for the Eighth Circuit · filed
In support of this claim, Nebraska cites the Second Circuit’s decision in Garcia. While the court in Garcia held that § 2000d-7 constitutes a clear conditional waiver, it also held that New York did not knowingly waive its Eleventh Amendment immunity from § 504 claims when it accepted federal funds for its medical school. Garcia, 280 F.3d at 113-15. ... In our view, the State’s argument is not well taken. ... We conclude that the State of Nebraska ought to have known, in 1996, that the validity of the abrogation statute was an issue litigable in good faith. Its decision to waive immunity by contract — an adequate and independent way of eliminating the Eleventh Amendment defense — was therefore knowing.
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The Fourth Circuit expressly declined to follow Garcia’s approach to knowing waiver of §504 Eleventh Amendment immunity and held that GMU waived immunity by accepting federal funds in 2003 under an unambiguous waiver condition.
Constantine v. Rectors and Visitors of George Mason University · United States Court of Appeals for the Fourth Circuit · filed
We decline to follow the Second Circuit's approach in Garcia. The Supreme Court has already held that a condition on federal spending must be clearly and unambiguously expressed so that the State accepting federal funds can be certain of its obligations upon receipt of such funds.
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Limited
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The Second Circuit confined Garcia's Title II discriminatory-animus requirement to Equal Protection-based claims and held it inapplicable where abrogation rests on the substantive due process right against unjustified involuntary commitment.
Bolmer v. Oliveira · United States Court of Appeals for the Second Circuit · filed
In sum, we hold with regard to DMHAS’s Eleventh Amendment immunity defense that (1) Garcia is not applicable when Congress’s abrogation is supported by its enforcement of the substantive due process right not to be involuntarily committed absent a danger to self or others; and (2) under Georgia and Lane, Congress validly abrogated states’ Eleventh Amendment immunity where the same conduct by the defendant violated both Title II and substantive due process.
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Questioned
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The district court questioned whether Garcia’s Title II discriminatory animus basis for damages remained viable after Tennessee v. Lane where no other fundamental right was implicated.
Roe v. Johnson · United States District Court for the Southern District of New York · filed
the Second Circuit Court of Appeals determined that Title II in its entirety is neither congruent nor proportional with the requirements of the Fourteenth Amendment and therefore limited monetary claims against the states under Title *422 II to those in which the plaintiff establishes that the violation was motivated by discriminatory animus or ill will based on the plaintiff's disability. Garcia, 280 F.3d at 109-111. Given the Supreme Court's decision in Lane, 124 S.Ct. 1978, it would appear that there is no longer any basis to find the existence of a cause of action under Title II where no other fundamental right is implicated and the sole justification is the defendant’s level of scien-ter.
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The Second Circuit questioned whether Garcia’s Title II damages rule remains valid after later Supreme Court decisions on state immunity.
Dean v. University at Buffalo School of Medicine & Biomedical Sciences · United States Court of Appeals for the Second Circuit · filed
Subsequent Supreme Court precedent concerning the constitutionality of Congress’s abrogation of Eleventh Amendment immunity under Title II calls Garcia ’s validity into question.
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