- Date:
- March 3, 1987
- Location:
- Florida
- United States
School Board of Nassau County v. Arline
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What was the School Board of Nassau County v. Arline case about?
School Board of Nassau County v. Arline was a U.S. Supreme Court case about whether someone with a contagious disease could be considered handicapped under Section 504 of the Rehabilitation Act of 1973.
The case centered on Gene Arline, an elementary school teacher who was fired after a third bout of tuberculosis. She sued, claiming that her dismissal was discrimination based on a handicap, which was prohibited under the Rehabilitation Act of 1973.
In 1987, the Supreme Court ruled that Arline's tuberculosis was a physical impairment that limited her ability to work. The Court also found that it was wrong to allow an employer to discriminate based on the effects of a disease on others.
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Who was Jean Arline, and why did she sue the school board?
Jean Arline was an elementary school teacher in Nassau County, Florida, who was discharged in 1979 after a third recurrence of tuberculosis. She sued the school board, claiming her dismissal was discrimination based on a handicap, which was prohibited under Section 504 of the Rehabilitation Act of 1973. According to the act, a handicapped individual is someone with a physical or mental impairment that substantially limits one or more of such person’s major life activities. The Supreme Court ruled that Arline's tuberculosis qualified as a handicap under the Rehabilitation Act, and sent the case back to the lower courts. The district court then ruled that Arline was "otherwise qualified" and ordered the school board to reinstate her or pay her salary.
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What disability was at the center of this case?
The disability at the center of School Board of Nassau County v. Arline was tuberculosis. The case revolved around Gene Arline, an elementary school teacher who was fired after recurring bouts of tuberculosis. The Supreme Court had to determine whether Arline's contagious disease qualified as a handicap under Section 504 of the Rehabilitation Act of 1973, which prohibits discrimination based on disability in federally funded programs. The court ruled that Arline's tuberculosis did qualify as a disability under the Rehabilitation Act.
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What law did the Supreme Court use to decide the case?
In School Board of Nassau County v. Arline, the U.S. Supreme Court utilized Section 504 of the Rehabilitation Act of 1973 to make its ruling. The case concerned Gene Arline, a teacher with recurring tuberculosis, who was dismissed due to her condition. Arline argued that her dismissal was discrimination based on a handicap, which is prohibited under Section 504 if the Rehabilitation Act.
The Supreme Court determined that Arline's tuberculosis qualified as a physical impairment that limited her life activities, thus considering her handicapped under Section 504. The Court rejected the school board's argument that Arline was dismissed due to health concerns for others, stating that employers could not discriminate based on the effects of a disease on others versus the effects on the patient.
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How did the Court decide whether someone with a contagious disease is protected under disability laws?
In School Board of Nassau County v. Arline, the Supreme Court ruled that a person with a contagious disease can be considered disabled under Section 504 of the Rehabilitation Act of 1973.
The case centered on Gene Arline, a teacher fired for recurring tuberculosis. The Court found that Arline's tuberculosis was a physical impairment that limited her ability to live her life, thus handicapped under Section 504.
The Court provided guidelines, derived from the American Medical Association, to determine if Arline was "otherwise qualified" for her job, considering the nature, duration, and severity of the risk of transmission, as well as the probabilities of harm. The case was remanded for further consideration, and the district court subsequently ruled that Arline was "otherwise qualified".
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Why is this case important for people with disabilities and workplace rights today?
School Board of Nassau County v. Arline is significant for disability rights and workplace protections because it established that individuals with contagious diseases can be considered handicapped under Section 504 of the Rehabilitation Act of 1973.
The Supreme Court's 1987 ruling stated that Gene Arline, a teacher with recurring tuberculosis, was protected from discrimination based on her condition. The court determined that Arline's tuberculosis qualified as a physical impairment that limited a major life activity, and rejected the school board's argument that her dismissal was due to health concerns rather than her capabilities.
This case set a precedent that employers cannot discriminate based on fears about a disease's effects on others, and it provided guidelines for assessing whether an individual is "otherwise qualified" for their job considering potential health and safety risks.
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School Board of Nassau County v. Arline, case in which the U.S. Supreme Court on March 3, 1987, ruled (7–2) that an individual with the contagious disease tuberculosis could be considered handicapped under Section 504 of the Rehabilitation Act of 1973.
The case centred on Gene Arline, an elementary school teacher in Nassau county, Florida, who had recurring lapses of tuberculosis. After a third bout with the disease, school board officials terminated her employment in 1979. Arline filed suit, claiming that because her dismissal constituted discrimination on the basis of a “handicap,” it was prohibited under Section 504 of the Rehabilitation Act of 1973, which provided:
No otherwise qualified individual with a disability…shall, solely by reason of his or her disability, 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.
The act further defined a handicapped individual as someone with “a physical or mental impairment which substantially limits one or more of such person’s major life activities.” Major life activities were understood to include walking, speaking, and breathing.
A federal district court in Florida ruled that Arline did not have a disability as defined by Section 504, and thus it entered a judgment in favour of the school board. However, the Eleventh Circuit Court of Appeals reversed, ruling that individuals with contagious diseases are covered by Section 504.
On December 3, 1986, the case was argued before the U.S. Supreme Court. In its decision the court found that Arline’s tuberculosis resulted in a physical impairment and, because she had been hospitalized for the illness, at least one major life activity had been limited. Therefore, Arline was handicapped as defined by Section 504. The court also rejected the school board’s argument that her impairment was irrelevant. According to the board, she was dismissed because her tuberculosis was a health concern to others, not because her physical capabilities were diminished. The court, however, held that it would be wrong to permit an employer to distinguish “between the effects of a disease on others and the effects of a disease on a patient and use that distinction to justify discriminatory treatment.”
The court next addressed the issue of whether Arline was “otherwise qualified” to do her job in light of the possible health and safety risks posed by her tuberculosis. To make such a determination, the court provided guidelines taken from an amicus curiae brief filed by the American Medical Association. Those guidelines required the consideration of
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(a) the nature of the risk (how the disease is transmitted), (b) the duration of the risk (how long is the carrier infectious), (c) the severity of the risk (what is the potential harm to third parties), and (d) the probabilities the disease will be transmitted and will cause varying degrees of harm.
Finding that the lower courts had not made findings of fact on those issues nor had they engaged in an analysis related to each factor, the Supreme Court remanded the case for further consideration. The district court subsequently ruled that Arline was “otherwise qualified.” Thus, it ordered the school board to reinstate her or pay her salary from the 1988–89 school year to her retirement.