What is the Alexander v. Choate law case about?

Alexander v. Choate is a legal case decided by the U.S. Supreme Court on January 9, 1985. The Court ruled unanimously that the state of Tennessee's reduction in the number of annual inpatient hospital days covered by Medicaid did not discriminate against disabled people, even though they were more likely to need longer hospital stays. The case began in 1984 when a group of Tennessee Medicaid recipients, some of whom were disabled, filed a class-action suit alleging that the proposed reduction from 20 to 14 annual inpatient hospital days violated Section 504 of the Rehabilitation Act of 1973. The plaintiffs argued that the reduction would adversely and disproportionately affect disabled patients, constituting discrimination under Section 504. The Supreme Court held that the reduction did not violate Section 504, finding that the 14-day hospital stay provided meaningful access, even if disabled persons were more likely to require longer stays. The Court also determined that Section 504 did not require Tennessee to forgo any limitation on hospital stays, because the cost of implementing an alternative Medicaid program without such limits would exceed reasonable accommodations. The judiciary has applied the theory of disparate impact beyond Title VII to a variety of other federal nondiscrimination statute titles and laws.

Who were the main people or groups involved in Alexander v. Choate?

Alexander v. Choate was a legal case involving several parties. The case originated in 1984 when a group of Tennessee Medicaid recipients, some of whom were disabled, filed a class-action suit against the state in federal district court. They alleged that Tennessee's proposal to reduce the number of annual inpatient hospital days covered by Medicaid from 20 to 14 days violated Section 504 of the Rehabilitation Act of 1973 . The state of Tennessee appealed to the Supreme Court, which heard oral arguments on October 1, 1984.

What question was the Supreme Court asked to decide in this case?

In Alexander v. Choate , the Supreme Court was asked to decide whether the state of Tennessee's reduction in the number of annual inpatient hospital days covered by Medicaid constituted discrimination against disabled persons under Section 504 of the Rehabilitation Act of 1973. The plaintiffs argued that the reduction from 20 to 14 days would disproportionately affect disabled Medicaid patients, who were more likely to require longer hospital stays, thus creating an adverse disparate impact amounting to discrimination. The Supreme Court unanimously ruled that the reduction did not violate the nondiscrimination requirements of Section 504, holding that the 14-day hospital stay provided meaningful access, and that Section 504 did not require Tennessee to forgo any limitation on hospital stays.

How did the case relate to rights for people with disabilities?

In Alexander v. Choate , the Supreme Court addressed whether Tennessee's reduction of Medicaid inpatient hospital coverage from 20 to 14 days discriminated against people with disabilities. Plaintiffs argued this violated Section 504 of the Rehabilitation Act of 1973, as disabled individuals might need longer hospital stays. The Court ruled that the reduction did not violate Section 504, clarifying that while accommodations must be reasonable to ensure meaningful access, Tennessee wasn't required to forgo all limitations on hospital stays, as the cost would be too high. The court held that the 14-day coverage provided meaningful access, even if it disproportionately affected disabled individuals.

What was the Supreme Court's decision in Alexander v. Choate?

In Alexander v. Choate (1985), the Supreme Court ruled 9-0 that Tennessee's reduction in Medicaid coverage for annual inpatient hospital days from 20 to 14 did not discriminate against disabled individuals, despite their likely need for longer hospital stays. The lawsuit was filed by Tennessee Medicaid recipients, who claimed the reduction violated Section 504 of the Rehabilitation Act of 1973, which prohibits discrimination based on disability in federally funded programs. The Court, in an opinion by Justice Thurgood Marshall, acknowledged Section 504 protects against disparate-impact discrimination. However, the Court held that the 14-day coverage provided meaningful access and that requiring Tennessee to eliminate all limitations would exceed reasonable accommodations, given the high costs. The ruling clarified that while disparate impact is a form of discrimination, the state wasn't obligated to redefine its Medicaid program.

How did Alexander v. Choate influence later laws or cases about disability rights?

Alexander v. Choate concerned whether reducing the number of hospital days covered by Medicaid in Tennessee was discrimination against disabled persons under Section 504 of the Rehabilitation Act of 1973. The Supreme Court ruled that the reduction did not violate Section 504, clarifying that while accommodations must be reasonable to ensure meaningful access, Tennessee was not required to forgo all limitations on hospital stays, as the cost would exceed reasonable accommodation. The court acknowledged Section 504 protects against disparate-impact discrimination, but the 14-day hospital stay provided meaningful access.

Alexander v. Choate

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Date:: January 9, 1985

Location:: Tennessee; United States

Key People:: Thurgood Marshall

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Alexander v. Choate

law case

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Julie F. Mead

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History

Top Questions

What is the Alexander v. Choate law case about?
Alexander v. Choate is a legal case decided by the U.S. Supreme Court on January 9, 1985. The Court ruled unanimously that the state of Tennessee's reduction in the number of annual inpatient hospital days covered by Medicaid did not discriminate against disabled people, even though they were more likely to need longer hospital stays.

The case began in 1984 when a group of Tennessee Medicaid recipients, some of whom were disabled, filed a class-action suit alleging that the proposed reduction from 20 to 14 annual inpatient hospital days violated Section 504 of the Rehabilitation Act of 1973. The plaintiffs argued that the reduction would adversely and disproportionately affect disabled patients, constituting discrimination under Section 504.

The Supreme Court held that the reduction did not violate Section 504, finding that the 14-day hospital stay provided meaningful access, even if disabled persons were more likely to require longer stays. The Court also determined that Section 504 did not require Tennessee to forgo any limitation on hospital stays, because the cost of implementing an alternative Medicaid program without such limits would exceed reasonable accommodations. The judiciary has applied the theory of disparate impact beyond Title VII to a variety of other federal nondiscrimination statute titles and laws.
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1. disparate impact: Application beyond Title VII
2. Alexander v. Choate
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Who were the main people or groups involved in Alexander v. Choate?
Alexander v. Choate was a legal case involving several parties. The case originated in 1984 when a group of Tennessee Medicaid recipients, some of whom were disabled, filed a class-action suit against the state in federal district court. They alleged that Tennessee's proposal to reduce the number of annual inpatient hospital days covered by Medicaid from 20 to 14 days violated Section 504 of the Rehabilitation Act of 1973. The state of Tennessee appealed to the Supreme Court, which heard oral arguments on October 1, 1984.
1 Britannica Source
1. Alexander v. Choate
Created from Britannica articles using AI. AI can make mistakes, so verify using Britannica articles.
What question was the Supreme Court asked to decide in this case?
In Alexander v. Choate, the Supreme Court was asked to decide whether the state of Tennessee's reduction in the number of annual inpatient hospital days covered by Medicaid constituted discrimination against disabled persons under Section 504 of the Rehabilitation Act of 1973. The plaintiffs argued that the reduction from 20 to 14 days would disproportionately affect disabled Medicaid patients, who were more likely to require longer hospital stays, thus creating an adverse disparate impact amounting to discrimination. The Supreme Court unanimously ruled that the reduction did not violate the nondiscrimination requirements of Section 504, holding that the 14-day hospital stay provided meaningful access, and that Section 504 did not require Tennessee to forgo any limitation on hospital stays.
1 Britannica Source
1. Alexander v. Choate
Created from Britannica articles using AI. AI can make mistakes, so verify using Britannica articles.
How did the case relate to rights for people with disabilities?
In Alexander v. Choate, the Supreme Court addressed whether Tennessee's reduction of Medicaid inpatient hospital coverage from 20 to 14 days discriminated against people with disabilities. Plaintiffs argued this violated Section 504 of the Rehabilitation Act of 1973, as disabled individuals might need longer hospital stays.

The Court ruled that the reduction did not violate Section 504, clarifying that while accommodations must be reasonable to ensure meaningful access, Tennessee wasn't required to forgo all limitations on hospital stays, as the cost would be too high. The court held that the 14-day coverage provided meaningful access, even if it disproportionately affected disabled individuals.
1 Britannica Source
1. Alexander v. Choate
Created from Britannica articles using AI. AI can make mistakes, so verify using Britannica articles.
What was the Supreme Court's decision in Alexander v. Choate?
In Alexander v. Choate (1985), the Supreme Court ruled 9-0 that Tennessee's reduction in Medicaid coverage for annual inpatient hospital days from 20 to 14 did not discriminate against disabled individuals, despite their likely need for longer hospital stays.

The lawsuit was filed by Tennessee Medicaid recipients, who claimed the reduction violated Section 504 of the Rehabilitation Act of 1973, which prohibits discrimination based on disability in federally funded programs. The Court, in an opinion by Justice Thurgood Marshall, acknowledged Section 504 protects against disparate-impact discrimination.

However, the Court held that the 14-day coverage provided meaningful access and that requiring Tennessee to eliminate all limitations would exceed reasonable accommodations, given the high costs. The ruling clarified that while disparate impact is a form of discrimination, the state wasn't obligated to redefine its Medicaid program.
3 Britannica Sources
Created from Britannica articles using AI. AI can make mistakes, so verify using Britannica articles.
How did Alexander v. Choate influence later laws or cases about disability rights?
Alexander v. Choate concerned whether reducing the number of hospital days covered by Medicaid in Tennessee was discrimination against disabled persons under Section 504 of the Rehabilitation Act of 1973.

The Supreme Court ruled that the reduction did not violate Section 504, clarifying that while accommodations must be reasonable to ensure meaningful access, Tennessee was not required to forgo all limitations on hospital stays, as the cost would exceed reasonable accommodation. The court acknowledged Section 504 protects against disparate-impact discrimination, but the 14-day hospital stay provided meaningful access.
1 Britannica Source
1. Alexander v. Choate
Created from Britannica articles using AI. AI can make mistakes, so verify using Britannica articles.

Alexander v. Choate, legal case in which the U.S. Supreme Court on January 9, 1985, ruled unanimously (9–0) that the state of Tennessee’s reduction in the number of annual inpatient hospital days covered by Medicaid (a health-insurance program for low-income persons run jointly by the federal government and the states) did not constitute discrimination against disabled persons, even though disabled persons were more likely to require longer hospital stays.

Alexander v. Choate arose in 1984 when a group of Tennessee Medicaid recipients, some of them disabled, filed a class-action suit in federal district court (on behalf of all Medicaid recipients in the state) alleging that Tennessee’s proposal to reduce from 20 to 14 the number of annual inpatient hospital days covered by Medicaid violated Section 504 of the Rehabilitation Act of 1973, which provided that:

No otherwise qualified handicapped individual…shall, solely by reason of his handicap, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance.

Citing a study of the 1979–80 fiscal year, the plaintiffs claimed that disabled Medicaid patients in Tennessee were more likely than nondisabled patients to require more than 14 days of hospital care annually; the study showed that 27.4 percent of disabled patients, but only 7.8 percent of nondisabled patients, required more than 14 days of care. For that reason, they argued, the proposed reduction would create an adverse disparate impact on disabled patients amounting to discrimination under Section 504. The plaintiffs additionally argued that any limitation whatsoever in the number of covered days would constitute disparate-impact discrimination, because disabled patients would be more likely than nondisabled patients to exceed it. After the district court dismissed the complaint, the Court of Appeals for the Sixth Circuit reversed in favour of the plaintiffs. The state then appealed to the Supreme Court, which heard oral arguments on October 1, 1984.

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In a unanimous opinion written by Justice Thurgood Marshall, the court held that the reduction did not violate the nondiscrimination requirements of Section 504. First, the court examined the issue of whether intent to discriminate was a necessary predicate to a finding of discrimination under Section 504. Although the court did not resolve this question, Marshall noted that both the legislative history of Section 504 and a comparison with other federal discrimination statutes such as Title VI of the Civil Rights Act of 1964 suggested that Section 504 was indeed designed to protect against disparate-impact discrimination. The court thus assumed that the law recognized such injuries and turned its attention to whether Tennessee’s actions in this instance were “the sort of disparate impact that federal law might recognize.”

Citing Southeastern Community College v. Davis (1979), “our major previous attempt to define the scope of [Section] 504,” the court acknowledged that, to avoid disparate-impact discrimination, a federal grantee must make “reasonable accommodations” in its program or benefit to “otherwise qualified handicapped individuals” in order to assure them “meaningful access to the benefit that the grantee offers.” However, in the court’s view the 14-day hospital stay that Tennessee allowed under its Medicaid program did provide meaningful access, even though persons with disabilities may be more likely than those without disabilities to require longer stays. In addition, the court held that Section 504 did not require Tennessee to forgo any limitation on hospital stays, because the enormous cost of implementing an alternative Medicaid program that did not incorporate such limits would clearly exceed the “reasonable accommodations” to which disabled persons are entitled under Davis. “As a result,” the court concluded, “Tennessee need not redefine its Medicaid program to eliminate durational limitations on inpatient coverage, even if in doing so the State could achieve its immediate fiscal objectives in a way less harmful to the handicapped.”

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