Gene Arline could no longer teach elementary school because she had tuberculosis, a contagious disease. The superintendent of schools in Nassau County, Florida dismissed her after it became clear that her illness was recurrent. The school system did not grant her financial relief. Arline claimed in a federal district court that this violated Section 504 of the Rehabilitation Act of 1973, which prohibits state-funded programs from denying relief to applicants solely because they are handicapped. The school conceded it dismissed her solely because of her illness, but contended that a contagious disease like tuberculosis did not qualify her as handicapped. The court ruled that the Act did not define contagious illnesses as handicaps, but the United States Court of Appeals for the Eleventh Circuit reversed. It found that Arline was "otherwise qualified" to teach except for her illness, and ruled that this qualified her for handicapped benefits.
Does Section 504 of the Rehabilitation Act of 1973, which provides relief to handicapped individuals, extend relief to individuals afflicted with contagious diseases?
Yes. Justice William J. Brennan Jr. delivered the opinion for a 7-2 court. The Court relied on the qualification criteria for "handicapped status" provided by the Department of Health of Human Services (HHS), which Congress authorized to implement the Act. HHS made it clear that the Act covers illnesses that cause a "record of impairment" upon a patient's "major life activities." The Court found that both the "contagious effects of a disease" and "the disease's physical effects" can impair the patient's ability to work. The Act intended to cover "those who are actually physically impaired, but also those who are regarded as impaired," since both conditions can prevent a patient from finding work.
Decisions
Decision: 7 votes for Arline, 2 vote(s) against Legal provision: Rehabilitation
Sort by Ideology
Full Opinion by Justice William J. Brennan, Jr.
