Parker诉阿拉巴马大学警察局等案

Kimber Leigh Parker, diagnosed with Cerebral Palsy since birth, worked as a police communications operator for the University of Alabama Police Department from October 2013 until her termination in December 2021. She alleged that her supervisors Melissa Bailey and Calvin Kimbrow repeatedly discriminated against her by denying reasonable accommodations, including use of a telephone headset, accessible parking, and restroom access. Parker also claimed coworkers harassed her with slurs and discriminatory comments, and that she was disciplined for tardiness caused by her disability. After complaining about discrimination from April to November 2021, she alleges no investigation was conducted and she was subsequently terminated. Defendants filed a Motion to Dismiss Parker's Second Amended Complaint, which was fully briefed and decided on December 10, 2024.

The court granted the Motion to Dismiss in part and denied it in part. Claims against individual defendants under the Rehabilitation Act were dismissed, as liability under that Act lies solely with the employer. The Board was found immune from suit under both Title I and Title II of the ADA, as the Eleventh Circuit had not established clear abrogation of immunity in employment discrimination contexts. Parker may only pursue prospective injunctive relief against Bailey and Kimbrow, not monetary damages or retroactive relief against the Board.

The central disputes were: (1) whether Parker could bring Rehabilitation Act claims against individual defendants Bailey and Kimbrow; and (2) whether the Board of Trustees of The University of Alabama was protected by sovereign immunity under the Eleventh Amendment from ADA claims. The court also considered whether Title II of the ADA validly abrogated state sovereign immunity in employment discrimination contexts.

The case highlights the limitations individuals with disabilities face when seeking redress against state entities and public university employers. The ruling underscores the interplay between the Rehabilitation Act, the ADA, and Eleventh Amendment sovereign immunity, demonstrating that while federal anti-discrimination laws provide important protections, state entities retain significant immunity from monetary damages in federal court. The decision may affect how disability discrimination claims against public universities are structured, potentially channeling plaintiffs toward prospective injunctive relief rather than damages.