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Community Integration 15 Years
After the Supreme Court’s
Olmstead Decision
Presentation to the
Disability Rights Consortium
April 23, 2014
Barry Taylor & Karen Ward
Equip for Equality
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Benjamin Wolf
ACLU of Illinois
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ADA and Community
Integration
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When Congress passed ADA it found:
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Segregation of people with disabilities was pervasive
problem in US
Discrimination included people in institutions
Segregation perpetuates unjustified assumptions
that institutionalized persons are incapable or
unworthy of participation in community life
Institutionalization severely diminishes everyday
activities like family relations, social contacts, work,
educational advancement, and cultural enrichment
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Department of Justice - ADA
Regulations
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DOJ: oversees Title II of ADA – covers state and
local government programs and services
Integration Mandate: State and local
governments must provide their services to
people with disabilities in the most integrated
setting appropriate to their needs
Most Integrated Setting: Setting that enables
people with disabilities to interact with nondisabled persons to the fullest extent possible.
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Olmstead – Case Background
Olmstead v. L.C. 527 U.S. 581 (1999)
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Two women with mental illness and DD
institutionalized in state-operated hospital in Georgia
Both deemed appropriate for community placement,
but remained institutionalized
Placement not provided because of insufficient
community resources
Sued under ADA’s integration mandate
Supreme Court: Unjustified institutionalization is
discrimination under the ADA.
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Factors Set forth by
Supreme Court in Olmstead
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Community integration requirements:
 Treatment officials find community is appropriate
 Person does not oppose placement in the community
 Placement can be reasonably accommodated taking
into account State resources & needs of other pwds
State can meet its ADA obligations if it has a:
 comprehensive, effectively working plan for placing
people with disabilities in less restrictive settings;
 waiting list that moves at a reasonable pace not
controlled by the State’s efforts to keep its institutions
fully populated.
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Comprehensive Effectively
Working Plan
Frederick L. v. Dep't of Pub. Welfare of Pa.,
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422 F.3d 151 (3rd Cir. 2005)
Class action on behalf of residents of a state
psychiatric hospital.
Plaintiffs: State does not have an Olmstead plan and
failed to provide “concrete, measurable benchmarks
and a reasonable timeline to ascertain when, if ever,
residents will be discharged to appropriate community
services.”
State: Just have to demonstrate “a commitment to take
all reasonable steps to continue past progress”
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Comprehensive Effectively
Working Plan
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Court: State’s generalized steps toward more
community services insufficient and do not constitute
an Olmstead plan
Olmstead plan must specify:
 the time-frame/target date for resident discharge;
 the approximate number of residents to be
discharged each time period;
 the eligibility for discharge; and
 a general description of the collaboration required
between the local authorities and the housing,
transportation, care, and education agencies to
effectuate integration into the community.
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Comprehensive Effectively
Working Plan
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Advocates Inc. v. Patterson, 653
F.Supp.2d 184 (E.D.N.Y. 2009)
 Crabtree
v. Goetz, 2008 WL 5330506 (M.D.
Tenn. Dec. 18, 2009)
 Williams
v. Quinn, 2014 WL 184948 (N.D. Ill.
Jan. 10, 2014)
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Frederick L. has been cited favorably by
courts across the country, including in Illinois:
 Disability
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Fundamental Alteration Defense
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DOJ Regulation: “A public entity shall make
reasonable modifications in policies, practices,
or procedures when the modifications are
necessary to avoid discrimination on the basis
of disability, unless the public entity can
demonstrate that making the modifications
would fundamentally alter the nature of the
service, program, or activity.” 28 CFR §
35.130(b)(7) (1998).
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Fundamental Alteration Defense
PA P&A v. PA Dep't of Public Welfare,
402 F. 3d 374 (3d Cir. 2005)
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Class action on behalf people living in a nursing facility
State: Funding shortages meant that it would be a
fundamental alteration to provide the requested
community services.
3rd Circuit: Budgetary constraints alone do not satisfy
the fundamental alteration defense. Demonstrating a
“commitment to action” to comply with the ADA is a
prerequisite to establishing a fundamental alteration
defense. Only when this is demonstrated do budgetary
issues even become a factor.
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Fundamental Alteration Defense
Fisher v. Oklahoma Health Care Auth.,
335 F.3d 1175 (10th Cir. 2003)
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State: Fundamental alteration if required to alter policy
that could lead to institutionalization – citing budgetary
constraints.
10th Circuit: Demonstrating a policy is “reasonable” in
light of the State’s fiscal crisis is not sufficient for
providing the fundamental alteration defense.
"If every alteration in a program or service that required
the outlay of funds were tantamount to a fundamental
alteration, the ADA's integration mandate would be
hollow indeed."
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Fundamental Alteration Defense
Arc of Washington v. Braddock,
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427 F.3d 615 (9th Cir. 2005)
Suit alleged insufficient community services – sought order
to require State to apply for increase in Home and
Community Based Waiver Program beyond current cap
State: Already significantly reduced institution population,
implemented an “Olmstead” plan, increased cap previously,
and significantly expanded budget for community services.
To require more would be a fundamental alteration.
9th Circuit: Forcing the state to apply for an increase in
its Medicaid waiver program cap constitutes a
fundamental alteration, and is not required by the ADA.
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Fundamental Alteration –
Leading Illinois Case
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Radaszewski v. Garner,
383 F.3d 599 (7th Cir. 2004)
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State unwilling to continue to provide same level of inhome nursing services when people turned 21.
State: fundamental alteration to provide the services
7th Circuit rejected the State’s position
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State already provided this service, just not at level
requested
Cheaper for the State to serve plaintiff in his home rather
than in a nursing home – undercut financial argument
Decision recently re-affirmed in Hampe v. Hamos, 917
F.Supp. 2d 805 (N.D. Ill. 2013)
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Private Facilities
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Although Olmstead involved state-operated
institution, courts have applied the case to
privately owned facilities that receive state funding
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Disability Advocates Inc. v. Patterson, 653 F.Supp.2d
184 (E.D.N.Y. 2009) – Adult Homes for people with MI
Ligas v. Hamos, 2006 WL 644474 (N.D. Ill. Mar. 7,
2006) – Intermediate Care Facilities for people with DD
Williams v. Quinn, 2006 WL 3332844 (7th Cir. Nov. 13,
2006) – Institutions for Mental Diseases (IMDs)
Colbert v. Quinn, 2008 WL 4442597 (N.D. Ill. Sept. 29,
2008) – Traditional nursing homes
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At Risk of
Institutionalization
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Courts have held that Olmstead decision includes
people who are “at risk” of institutionalization.
Fisher v. Oklahoma Health Care Auth., 335 F.3d 1175
(10th Cir. 2003),
 State imposed five prescription drug cap for people in
the community – no such cap for nursing home residents
 Court: Violation of the ADA's integration mandate – puts
people at risk of institutionalization in nursing home
 Olmstead not limited to people in institutions. Persons
"who, by reason of a change in state policy, stand
imperiled with segregation," may challenge that policy
under the integration mandate.
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At Risk of
Institutionalization
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Illinois courts agree that Olmstead extends to people at
risk of institutionalization
 Bruggeman ex rel. Bruggeman v. Blagojevich, 324
F.3d 906 (7th Cir. 2003), adults with developmental
disabilities waiting for community services at home are
covered by Olmstead decision.
 Radaszewski v. Garner, 383 F.3d 599 (7th Cir. 2004),
plaintiff at risk of institutionalization if state did not continue
to provide in-home nursing services received as a child.
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Ligas v. Maram, 2006 WL 644474 (N.D. Ill. Mar. 7, 2006),
class certification included people who are at risk of
institutionalization if not provided services.
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Children and Olmstead
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Although Olmstead involved adults with disabilities,
cases are now being brought on behalf of kids
A.R. v. Dudek, 1:12-cv-60460 (S.D. Fla. 2012) and U.S.
v. Florida , 1:13-cv-61576 (S.D. Fla. 2013)
 Children with disabilities unnecessarily segregated
in nursing facilities instead of being served in their
family homes or other community-based settings.
 State's policies place other children with significant
medical needs in the community at serious risk of
institutionalization in nursing facilities.
 Case brought under ADA and Medicaid.
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Children and Olmstead
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T.R. v. Quigley, 2:09-cv-01677-TSZ (W.D. WA 2013)
State of Washington sued for failing to provide
adequate home and community-based mental health
services for children. Medicaid and ADA claims.
Suit brought on behalf of kids currently institutionalized
and kids at risk of institutionalization if they do not
receive the mental health services they need.
On 12/19/13, court approved an agreement which
would significantly expand community mental health
services for kids in Washington.
http://www.disabilityrightswa.org/settlement-statewide-classaction-approved-court
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Children and Olmstead in
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N.B. v. Hamos, 11:06866 (N.D. Ill.)
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Nine children with mental illness sued the Director of
the Illinois Department of Healthcare and Family
Services for failing to provide adequate home and
community-based mental health services. Case
alleges violation of Medicaid, ADA and Rehab Act.
ADA Claim - Children at risk of institutionalization if
they do not receive the mental health services they
need.
On 2/13/14, court certified case as a class action 2014 WL 562637
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Children Becoming Adults
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Illinois has a program that provides in-home
nursing services to kids with disabilities called the
Medically Fragile Technology Dependent (MFTD)
waiver.
However, when kids turn 21, they “age out” of this
program. Under the adult program, their services
are dramatically reduced.
As a result of this reduction in services, people “at
risk” of institutionalization upon turning 21.
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Children Becoming Adults
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Individual Cases: Numerous cases secured relief for
individuals at risk of institutionalization, but no change in
policy:
 Radaszewski v. Garner, 383 F.3d 599 (7th Cir. 2004)
 Grooms v. Maram, 563 F.Supp.2d 840 (N.D. Ill. 2008)
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Class Action - Hampe v. Hamos, 10 C 2031 (N.D. Ill.)
Brought on behalf of all people aging out of Illinois’
MFTD waiver - at risk of institutionalization
 Agreement reached that a person’s medical services
will be based on medical necessity, not chronological
age. http://www.farley1.com/hampe-consent.html
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Budget Cuts and Olmstead
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Olmstead has also been applied to cases in which
State is proposing to reduce or eliminate community
services placing people at risk of institutionalization
Crabtree v. Goetz, 2008 WL 5330506 (M.D. Tenn. Dec. 19,
2008)
adults with disabilities receiving in-home nursing care
at risk of institutionalization when Tennessee
proposed significantly cutting funding for home health
care services.
 Preliminary injunction granted to prevent
implementation of cuts while litigation is pending.
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Budget Cuts and Olmstead
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V.L. v. Wagner, 2009 WL 3486708
(N.D. Cal. Oct. 23, 2009)
California proposed reducing or terminating in-home
support services for elderly and people with disabilities.
Plaintiffs filed suit to prevent service cuts claiming
violation of ADA because proposed cuts would place
plaintiffs at risk of institutionalization.
Court: Budget cuts could violate the ADA’s integration
mandate. Accordingly, the court issued a preliminary
injunction, which prevents budget cuts from taking
place while litigation is pending.
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Budget Cuts and Olmstead
Pashby v. Cansler,
2011 WL 6130819 (E.D.N.C. Dec. 8, 2011),
affirmed, 709 F.3d 307 (4th Cir. 2013)
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Adults with disabilities challenged a new state Rule
that would terminate coverage for in-home services.
Plaintiffs filed suit under the ADA to prevent the Rule
from being implemented under a ADA. Specifically,
the plaintiffs are claiming that the Rule would
unjustifiably put them at risk of institutionalization.
The court granted motion for a preliminary injunction
that prevents new Rule from being implemented while
the litigation is pending. Injunction affirmed on appeal.
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Employment and Olmstead
Lane v. Kitzhaber, 841 F. Supp. 2d 1199 (D. Ore. 2012)
Suit filed by eight individuals with ID/DD who qualify for or
receive employment services from State.
Allegations:
 Plaintiffs are able and would prefer to work in an integrated
employment setting.
 Plaintiffs are segregated in sheltered workshops and denied
contact with people without disabilities.
 Defendants filed motion to dismiss.
 Court granted motion to dismiss, but gave plaintiffs
opportunity to amend, and made various conclusions in its
order.
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Employment and Olmstead
Lane v. Kitzhaber (cont.)
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Court: Title II’s Integration Mandate Applies to the
Provision of Employment-Related Services
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Relied on DOJ’s guidance that an Olmstead plan includes
people in sheltered workshops or segregated day programs.
Court: Granted motion to dismiss so that Plaintiffs could
clarify allegations that State is violating the ADA by denying
employment services to plaintiffs for which they are eligible
with the result of segregating them in sheltered workshops
 Amended complaint: Plaintiffs filed on 5/29/12;
 Class certification granted. Lane v. Kitzhaber, 283 F.R.D.
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587 (D. Ore. 2012).
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Employment and Olmstead
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U.S. v. Rhode Island and City of Providence
1:13-cv-00442 (D.R.I. 2013)
DOJ investigation: State and City unnecessarily
segregated approximately 200 people with disabilities
in 2 sheltered workshop programs
State/City entered into a court-enforceable interim
settlement agreement– DOJ will continue its state-wide
investigation
Goal: Achieve integration for individuals who can and want
to work but who have remained unnecessarily in workshops
Complaint. Agreement, Press Release, Fact Sheets:
www.ada.gov/olmstead/olmstead_cases_list2.htm#ri
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Employment and Olmstead
U.S. v. Rhode Island – 1:14-cv-00175 – (D.R.I. 2014)
 DOJ entered into agreement with RI as state’s system
violates the ADA by over-relying on segregated settings,
including sheltered workshops and facility-based day
programs, to the exclusion of integrated alternatives.
 Under the agreement, RI will provide supported
employment placements to approximately 2,000
individuals, including
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at least 700 people currently in sheltered workshops,
at least 950 people currently in facility-based non-work
programs, and
approximately 300-350 students leaving high school.
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Employment and Olmstead
U.S. v. Rhode Island – 1:14-cv-00175 – (D.R.I. 2014)
Agreement Provides:
 sufficient services to support normative 40 hour work week,
 expectation that individuals will work, on average, in a
supported employment job at competitive wages for at least
20 hours per week.
 State will provide transition services to approximately 1,250
youth between 14 and 21 intended to lead to integrated
employment outcomes after secondary school.
To View Letter of Finding, Complaint, Agreement, Order,
Press Release and Fact Sheet Go To:
http://www.ada.gov/olmstead/olmstead_cases_list2.htm#ri-state
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“Reverse” Olmstead
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Some have tried to use the Olmstead decision to
prevent the closure of institutions
They argue that the following dicta in Olmstead
supports their position:
 “nothing in the ADA or its implementing regulations
condones” forcing disabled persons into community
settings when they are “unable to handle or benefit”
from them, and
 there is no “federal requirement that communitybased treatment be imposed on patients who do not
desire it.” See Olmstead 527 U.S. at 601–02, 604.
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“Reverse” Olmstead Background
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Early court decisions rejected using Olmstead to
prevent closure of institutions
Richard S. v. Department of Developmental
Services, 2000 WL 35944246 *3 (C.D. Cal. March 2000) there is no basis [in Olmstead ] for saying that a
premature discharge into the community is
ADA discrimination based on disability.”
Richard C. v. Houstoun, 196 F.R.D. 288, 292 (W.D. Pa.
1999) - “it does not logically follow [from Olmstead ] that
institutionalization is required if any of the three
Olmstead criteria is not met”
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“Reverse” Olmstead –
Recent Case
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Sciarillo v. Christie,
2013 WL 6586569 (D.N.J. Dec. 13, 2013)
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Case filed by people with disabilities through their
guardians seeking to prevent closure of two state
developmental centers.
Argument: Closure of facilities and involuntary transfer
to another institution violates ADA and inconsistent
with Olmstead.
Court: “Plaintiffs’ interpretation of Olmstead is
untenable.” Relocating residents to another institution
when their current facility is closed is not discrimination
based on disability.
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“Reverse” Olmstead –
Recent Case in Illinois
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IL League of Advocates for the Developmentally
Disabled v. Quinn, 2013 WL 3168758 (N.D. Ill. 6/20/2013)
Suit filed on behalf of people with developmental
disabilities in state-operated DD institutions who do not
want to move into the community. Suit was filed after
Governor announced plans to close two of the state
institutions
Allegations included claim that closure would violate the
ADA and would be contrary to the Olmstead decision.
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“Reverse” Olmstead –
Recent Case in Illinois
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ILADD v. Quinn (cont.)
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Court:
 Dismisses Olmstead claim
 “this is not an Olmstead case. Plaintiffs do not claim
they have been or will be deprived of placement in a
community living environment—quite the contrary.
They oppose such placement and, thus, do not fall
within Olmstead' s purview. Unjustified isolation
constitutes discrimination under the ADA, but—based
on our close reading of Olmstead and the few relevant
authorities—it does not follow from Olmstead that the
converse is true.”
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“Reverse” Olmstead –
Recent Case in Illinois
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ILADD v. Quinn (cont)
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Court Open to Possible Non-Olmstead Title II Claims:
Even though the judge found that Olmstead not applicable in
this case, he ruled that a Title II claim under the ADA may be
established by evidence that:
(1) the defendant intentionally acted on the basis of
disability,
(2) the defendant refused to provide a reasonable
modification, or
(3) the defendant's rule disproportionally impacts disabled
people.
Parties have briefed this issue as part of a motion for
preliminary injunction – no decision yet by the judge.
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DOJ and Olmstead
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Previous administration brought no affirmative
community integration litigation after Olmstead decision
Current administration has been very pro-active on
bringing Olmstead cases and filing Statements of
Interest in support of others’ Olmstead cases
www.ada.gov/olmstead/olmstead_enforcement.htm lists
the 50 Olmstead cases in which DOJ is involved.
DOJ has also issued a Statement on Olmstead that has
been cited favorably by courts and can be very helpful
to advocates
http://www.ada.gov/olmstead/q&a_olmstead.htm
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What Led to Filing Community
Integration Cases in Illinois
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ADA’s “Integration Mandate” and Supreme
Court’s decision in Olmstead
Illinois’ over-reliance upon institutional settings
Various post-Olmstead efforts by State did not
result in meaningful change
No response from Governor to letter sent by
advocates
EFE, ACLU of IL and Access Living joined to
bring three Olmstead class actions
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Ligas v. Hamos
Case Background
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Suit filed in 2005 by 9 individuals with DD
Nearly 6000 people living in large private ICFDDs (9
or more) and thousands more living at home “at risk
of institutionalization”
Suit did not cover DD State-Ops or kids
Suit brought by Access Living, ACLU, Equip for
Equality and Dentons (pro bono law firm)
Certified as Class Action: Class included both
people in institutions and people living at home
waiting for services. 2006 WL 644474 (N.D. Ill. Mar.
7, 2006)
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Ligas Case Background (cont.)
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Agreement reached with State, but class decertified and agreement rejected by court based
on concerns raised by guardians who wanted
their family members to stay in the institutions.
After extensive negotiations, the Plaintiffs, the
State, and the Intervenors (those opposed to the
original agreement) reached a new agreement
that all could support.
Judge certified new class and granted approval
of new agreement in June 2011.
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Terms of Ligas Decree
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Over 6 year period, all ICFDD residents who make
a record of wanting community services will move
into the community.
All ICF-DD residents happy with their current
placement are not in the class and would not be
required to move.
Additional 3,000 people living at home waiting for
services will receive community services
After 6 years, State must develop waiting list that
moves at reasonable pace.
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Current Status of Ligas decree
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Independent Monitor appointed – Tony Records
Over 2000 class members have received
community based services
Current concerns about size of placement,
employment options, placements from
involuntary closures, and challenges to OSG
Complaint, Consent Decree, Implementation Plans,
Monitor Reports and Fact Sheet can be found at:
http://www.equipforequality.org/learn/rights-information-by-topicarea/resources-community-integration/
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Williams v. Quinn case background
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Suit on behalf of people with mental illness living in
IMDs (Institutions for Mental Diseases)
Approximately 4,500 people resided in IMDs
statewide
Case brought by ACLU, Access Living, Bazelon
Center, Equip for Equality and Kirkland & Ellis (pro
bono law firm)
Certified as a class action in 2006 - 2006 WL
3332844 (7th Cir. Nov. 13, 2006)
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Williams v. Quinn – Consent Decree
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Consent Decree was approved on 9/29/10
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Over 5 year period, all IMD residents not
opposing community services shall be placed in
the most integrated community-based setting
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Permanent Supportive Housing will be
considered most integrated setting for the vast
majority of class members
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Illinois will get new federal money to support
community services
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Current Status of Williams decree
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Independent Monitor appointed – Dennis Jones
882 class members transferred to the community
through 3/31/14
Challenge to implementation of Consent Decree
by IMD owners rejected by court - 2014 WL
184948 (N.D. Ill. Jan. 10, 2014)
Complaint, Consent Decree, Implementation Plans,
Monitor Reports and Fact Sheet can be found at:
http://www.equipforequality.org/learn/rights-information-by-topicarea/resources-community-integration/
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Colbert v. Quinn
Case Background
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Community integration litigation on behalf of
people with disabilities living in nursing homes
Limited to Cook County
Certified as a class action in 2008 - 2008 WL
4442597 (N.D. Ill. Sept. 29, 2008)
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U IP F
Over 16,000 class members – class comprised of
people with physical disabilities and mental illness
Attorneys representing class: ACLU, Dentons (pro
bono law firm) and Equip for Equality
Consent Decree Approved – 12/11/11
Independent Monitor Appointed – Dennis Jones
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EQ
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U IP F
U A LIT
Current Status of Colbert Decree
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300 class members were to be moved to a
community based setting in the first year
DHFS was designated lead agency for
implementation - heavy reliance upon managed care
State only placed 80 people after the first year –
Monitor found State out of compliance
State re-designated lead agency to Dept. on Aging –
new Implementation Plan to be filed 7/1/14
Complaint, Consent Decree, Implementation Plan, Monitor
Report and Fact Sheet can be found at:
http://www.equipforequality.org/learn/rights-information-by-topicarea/resources-community-integration/
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QUESTIONS?
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Community Integration 15
Years After the Supreme
Court’s Olmstead Decision
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U IP F
U A LIT