Lee-Thomas v. Prince George’s County Public Schools, No. 10-1699
Decided: January 11, 2012
Hope Lee-Thomas, an employee of the Prince George’s County Public School Board, alleged that the Board violated the Americans with Disabilities Act by failing to reasonably accommodate her hearing disability. The Board contends that the district court erred in deferring to the decision of the Court of Appeals of Maryland in Board of Education of Baltimore County v. Zimmer-Rubert on the question of whether the immunity provision state, which effectuated a waiver of a county board of education’s Eleventh Amendment immunity for all claims in the amount of $100,000 or less, waived the State’s Eleventh Amendment immunity. The Board posits that no such deference is owed because the question is one of federal law, on which the decisions of the Supreme Court of the United States are controlling. The Fourth Circuit Court of Appeals determined that, although federal courts must apply federal law as embodied in Supreme Court precedent, when a state’s highest court has applied federal law and determined that a state statute effects a waiver of Eleventh Amendment immunity, the federal courts must accord deference to that state court decision. Therefore, the Fourth Circuit affirmed, and held that the district court properly deferred to the decision of the Court of Appeals of Maryland.
-Sara I. Salehi