Board of Trustees of the University of Alabama v. Garrett, 531 U.S. 356 (2001), was a United States Supreme Court case about Congress's enforcement powers under the Fourteenth Amendment to the United States Constitution. The Supreme Court decided that Title I of the Americans with Disabilities Act was unconstitutional, insofar as it allowed states to be sued by private citizens for money damages. Background The plaintiffs were Milton Ash and Patricia Garrett, both employees of the University of Alabama school system. They were disabled under the definition of the Americans with Disabilities Act (ADA). Ash was a security guard who had a lifelong history of severe asthma, and Garrett was a nurse who had been diagnosed with breast cancer requiring time-consuming radiation and chemotherapy treatments. Both alleged that they had been discriminated against at their jobs. The university had refused to assign Ash to duties that would alleviate his asthma and insisted on transferring Garrett because of her absences. Ash and Garrett filed a suit in federal court against the University of Alabama for damages, arguing that the university had violated Title I of the ADA, which prohibiting discrimination in employment on the basis of disability. The University of Alabama responded with a motion to dismiss on the grounds that the Eleventh Amendment prohibited the suit. The United States District Court for the Northern District of Alabama dismissed both cases on that ground, but the Eleventh Circuit reversed and held that Congress had expressly abrogated the sovereign immunity of the states. Issue Can Congress abrogate states' immunity under its Fourteenth Amendment power to enforce the Equal Protection Clause? Decision The majority opinion stated that Congress, in enacting the ADA, had satisfied the requirement that it make clear its intention to abrogate state sovereign immunity and allow states to be sued for damages under the Fourteenth Amendment. However, the majority opinion also stated that part of the ADA to lack the "congruence and proportionality" required when Congress exercises its enforcement power under the Fourteenth Amendment, citing City of Boerne v. Flores (1997). Under the Equal Protection Clause, discrimination against people with disabilities is analyzed by "rational basis" scrutiny: if the discrimination has a rational basis, it is constitutional. In this case, the Court held that Congress, like the judiciary, was required to use rational basis review of state action, with its presumptions favoring constitutionality. The Supreme Court decided that the legislative