School Board of Nassau County v. Arline Case Brief Summary | Law Case Explained

School Board of Nassau County v. Arline | 480 U.S. 273 (1987)

Although tuberculosis is no longer an automatic death sentence, people who live with tuberculosis can relapse and become contagious again after an initial infection. In School Board of Nassau County versus Arline, we’ll see whether a person with recurrent tuberculosis is protected from discrimination under the Rehabilitation Act of 1973.

Gene Arline was hospitalized with tuberculosis in 1957. Arline eventually recovered, and her tuberculosis went into remission. In 1966, Arline began working as an elementary schoolteacher in Nassau County, Florida. In 1977, cultures revealed that Arline’s tuberculosis had become active again. In March and November of 1978, Arline relapsed again. After Arline’s relapses, the school board suspended her with pay for the remainder of the school year. At the end of the school year, in 1979, the school board discharged Arline from her teaching job. The school board admitted that it only dismissed Arline because of her recurrent tuberculosis and not because she did anything wrong.

Arline sued the school board. Arline claimed that her tuberculosis made her a handicapped individual, so the school board violated Section 504 of the Rehabilitation Act when it dismissed her. Section 504 prohibits any federally funded program from discriminating against an otherwise qualified handicapped individual solely because of the person’s handicap. The district court acknowledged that Arline suffered from a handicap as a result of her tuberculosis but concluded that she wasn’t a handicapped individual, as defined by the act. As a result, the school board didn’t violate the act when it dismissed Arline. Arline appealed. The court of appeals reversed the district court’s holding and held that people with contagious diseases fall within the definition of handicapped in the act. The court of appeals remanded the case on the issue of whether Arline’s tuberculosis prevented her from being otherwise qualified for her job. The United States Supreme Court granted cert.

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