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Ivy v. Morath

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Supreme Court of the United States
Ivy v. Morath
Docket number: 15-486
Term: 2016
Court: United States Supreme Court
Important dates
Argument: Unargued
Decided: October 31, 2016
Court membership
Chief Justice John G. Roberts • Anthony Kennedy • Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan


Ivy v. Morath is a case docketed for oral argument during the October 2016 term of the U.S. Supreme Court. Argument in the case was scheduled for November 7, 2016, however the judgment in the case was vacated and the case was remanded to the United States Court of Appeals for the 5th Circuit with instructions to dismiss the case as moot on October 31, 2016.[1]

HIGHLIGHTS
  • The case: Deaf individuals in Texas sued the Texas Education Agency (TEA) in order to bring driver education schools licensed by the TEA into compliance with the Americans with Disabilities Act and the Rehabilitation Act. The Fifth Circuit dismissed the case, finding that drivers education did not meet the statutory definition of a "service, program, or activity" of the state of Texas.
  • The issue: Does Texas' scheme for driver education function as a service, program, or activity of a public entity under federal law?
  • The outcome: The judgment in the case was vacated and the case was remanded with instructions to dismiss the case as moot.


    • In brief: Texas law requires driver's education certificates as a prerequisite for obtaining a driver's license for anyone under 25 years of age. The state outsources driver's education programs to private companies which are licensed by the Texas Education Agency (TEA). In this class action, a class of hearing-impaired individuals sued the TEA under the Americans with Disabilities Act (ADA) and the Rehabilitation Act when no licensed drivers education school would accommodate their disability and the state did not exempt the individuals from the certification requirement. Texas sought to dismiss the case, but a federal district court denied Texas' motion. The Fifth Circuit reversed, finding that the driver education programs were not a service, program, or activity of the TEA. On October 31, 2016, the judgment in the case was vacated and the case was remanded with instructions to dismiss the case as moot.[1]

    You can review the Fifth Circuit's opinion here.[2]

    Click on the tabs below to learn more about this Supreme Court case.

    Case


    Background

    Texas law stipulates that anyone under 25 years of age cannot get a driver's license unless a driver education certificate is submitted to the Texas Department of Public Safety (DPS). Texas outsources drivers education to private driver education schools which are licensed by the Texas Education Agency (TEA). A school must be licensed by the TEA in order to issue certifications accepted by the DPS. Texas law provides only two alternatives to private driver education schools in order to receive certification: "individuals may receive driver education certificates by taking a class taught by a parent or another specified close relative" or "individuals can obtain driver education certificates from driver education classes offered at public schools."[3]

    The plaintiff in this case, Donnika Ivy, contacted numerous TEA-licensed driver education schools in the hope of getting certified. None of the schools she contacted would accommodate her disability, which prevented Ivy from obtaining certification. A state agency specialist informed the TEA of the inability of deaf individuals to obtain certification, but the TEA declined to intervene, "stating that it was not required to enforce the ADA and that it would not act against the private driver education schools unless the United States Department of Justice found that the schools had violated the ADA." The specialist filed a complaint against the TEA with the Department of Justice, "which the DOJ apparently dismissed."[3]

    Ivy filed a lawsuit in federal district court against both the TEA and the private driver education schools. She later dismissed the schools from her lawsuit. The lawsuit developed into a class-action lawsuit with multiple plaintiffs and the TEA remaining as the lone defendant. The plaintiffs sought an order requiring the TEA to bring driver education courses into compliance with the Americans with Disabilities Act (ADA). The TEA filed a motion to dismiss the case, arguing that the plaintiffs lacked standing and that they failed to state a claim. The district court denied TEA's motion to dismiss, but stayed the case pending an interlocutory appeal before the Fifth Circuit Court of Appeals on the district court's denial of TEA's motion.[3]

    The Fifth Circuit held that the plaintiffs had proven standing in the case, but that they failed to state a claim. According to the court's opinion, in order to obtain relief under Title II of the Americans with Disabilities Act and the Rehabilitation Act, the plaintiffs had to demonstrate that they had been "excluded from participation in or ... denied the benefits of the services, programs, or activities of [the TEA] ... To answer that question, we must decide whether driver education is a service, program, or activity of the TEA. We hold that it is not, although this is a close question for which the statutes, regulations, and case law provide little concrete guidance."[3]

    In the court's view, because the U.S. Supreme Court has interpreted the language of the ADA's Title II that "services, programs, or activities of a public entity" is limited to those which are provided by the public entity, and because the state did not provide drivers education but only licensed and regulated the schools that did, the Fifth Circuit reasoned that driver education was not a "program, service or activity of the TEA" and was not subject to regulation under Title II. Similarly, the Fifth Circuit reasoned that the TEA's activity did not rise to the definition of "program or activity" under the Rehabilitation Act. The Fifth Circuit reversed the district court's denial of the TEA's motion and dismissed the case with prejudice "for failure to state a claim upon which relief can be granted."[3] Ivy appealed to the Supreme Court of the United States.

    Petitioner's challenge

    Ivy was going to challenge the Fifth Circuit's holding that, despite the TEA's "pervasive involvement in every aspect of a state-mandated, driver-education program," the TEA's involvement "did not rise to the level of a 'service, program, or activity' of the state'" for purposes of enforcement under the Americans with Disabilities Act and the Rehabilitation Act. The judgment in the case was vacated and the case was remanded with instructions to dismiss the case as moot on October 31, 2016.[4][1]

    Certiorari granted

    On October 14, 2015, petitioners Donnika Ivy et al. initiated proceedings in the Supreme Court of the United States in filing a petition for a writ of certiorari to the United States Court of Appeals for the 5th Circuit. The U.S. Supreme Court granted Ivy's certiorari request on June 28, 2016.

    Arguments

    Question presented

    Question presented:

    "Did the Fifth Circuit err in deciding that the relationship between public and private actors does not invoke dual obligations to accommodate in any context other than an express contractual relationship between a public entity and its private vendor?"[4]


    Outcome

    The judgment in the case was vacated and the case was remanded with instructions to dismiss the case as moot on October 31, 2016.[1]

    Filings

    The court granted Ivy's certiorari request on June 28, 2016.

    Merits filings

    Parties' filings

    • Donnika Ivy et al., the petitioners, filed a merits brief on August 23, 2016.

    Amicus curiae filings

    The following groups filed amicus curiae briefs in support of the petitioners, Donnika Ivy et al.

    • Brief of the National Association of Counties et al.
    • Brief of the National Association of the Deaf et al.
    • Brief of Paralyzed Veterans of America et al.
    • Brief of Texas Business Women Inc. et al.
    • Brief of the United States of America (position supporting that the judgment be vacated)
    • Brief of various law professors

    Certiorari filings

    Parties' filings

    • Donnika Ivy et al., the petitioners, filed a petition for certiorari on October 14, 2015.
    • Mike Morath, Texas Commissioner of Education, the respondent, filed a brief in opposition to certiorari on January 22, 2016, after two orders extending time to file were granted by the court.

    Amicus curiae

    The following group filed an amicus curiae brief in support of denying certiorari

    • Brief of the United States of America


    See also

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 Supreme Court of the United States, "Order list - 580 U.S.," October 31, 2016
    2. ↑ U.S. Court of Appeals for the Fifth Circuit, Donnika Ivy et al. v. Commissioner Michael Williams, in his official capacity as head of the Texas Education Agency decided March 24, 2015
    3. ↑ 3.0 3.1 3.2 3.3 3.4 Cite error: Invalid <ref> tag; no text was provided for refs named Fifth
    4. ↑ 4.0 4.1 Supreme Court of the United States, Ivy v. Morath, June 28, 2016
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