Last week, we lost a pioneer in the disability rights movement. Lois Curtis, one of the two plaintiffs in the landmark case Olmstead v. L.C., died of pancreatic cancer on Nov. 3, 2022. Ms. Curtis (“L.C.”), together with another woman, Elaine Wilson, sued the State of Georgia under the Americans with Disabilities Act (ADA) to challenge her unnecessary institutionalization in a state psychiatric hospital. Their case was heard by the Supreme Court in 1999, resulting in a landmark decision concluding that unnecessary institutionalization of people with disabilities is a form of discrimination prohibited by the ADA.
Ms. Curtis will be remembered for the lasting impact that her advocacy had on the lives of people with disabilities. The Olmstead decision has resulted in dramatic changes in how states and local governments provide services to people with disabilities. The decision requires investments in community services that people with disabilities need to live in their own homes and be full participants in their communities.
Ms. Curtis had experienced repeated institutionalizations since her childhood. When she filed her case under the ADA, she and Ms. Wilson, who were both diagnosed with intellectual and psychiatric disabilities, had remained institutionalized in Georgia Regional Hospital for several years after the hospital identified them as ready for discharge. Ms. Curtis and Ms. Wilson were represented by the Atlanta Legal Aid Society, and won their case in the trial court. Their victory was affirmed by the Eleventh Circuit Court of Appeals, and ultimately the Supreme Court ruled in their favor as well. The Supreme Court observed in its decision that needless institutionalization “perpetuates unwarranted assumptions that persons so isolated are incapable or unworthy of participating in community life,” and that institutional confinement “severely diminishes the everyday life activities of individuals, including family relations, social contacts, work options, economic independence, educational advancement, and cultural enrichment.”
While there is still a long way to go to achieve the goals of the ADA’s integration mandate and the Olmstead decision, Ms. Curtis’s advocacy fueled a movement that has enabled many thousands of people with disabilities to get the services they need to live, work, and thrive in integrated settings. She was a remarkable woman whose work paved the way for so many adults and children with disabilities to live full lives in their communities. The Department of Justice will continue to honor her legacy through its work to enforce the rights that she helped make a reality.
The Department of Justice Civil Rights Division has enforced the Olmstead decision in states across the country. Information about the Olmstead case and the department’s work in this area can be found at https://www.ada.gov/olmstead/olmstead_about.htm.
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