2001 Cases
Attorney's Fees
Buckhannon Board & Care Home, Inc. v. West Virginia Department of Health & Human Resources
Issue: Whether federal statutes that allow courts to award attorney's fees and costs to the "prevailing party" authorize awards of fees to parties whose lawsuits brought about voluntary changes in the defendants' conduct but did not result in judgments on the merits or court ordered consent decrees.
The Court held that the "catalyst theory" is not a permissible basis for the award of attorney's fees under the FHAA and ADA.
Modification of Policy and Procedure
K. PGA Tour, Inc. v. Martin, 532 U.S. 661, 121 S.Ct. 1879 (2001)
Issue: Whether Title III of ADA protects qualified entrants with disabilities participating in professional golf tournaments, and whether allowing a golfer with a disability to use a golf cart when all other competitors must walk would "fundamentally alter the nature" of the tournaments.
The Court held that Title III of the ADA, by its plain terms, prohibits the PGA from denying Martin equal access to its tours based on his disability and that allowing Martin to use a cart, despite the walking rule, is not a modification that would "fundamentally alter the nature" of the game.
Punitive and Compensatory Damages
Board of Trustees of University of Alabama v. Garrett (2001)
Issue:Whether the Eleventh Amendment bars employees of a state from recovering monetary damages from the state for violations of Title I of ADA.
The Court denied the right of employees to sue their employers for money damages for violations of Title I of the Americans with Disabilities Act (ADA), which prohibits discrimination against people with disabilities.
