Tommy Olmstead Commissioner Georgia Department of Human Resourcess v. L C Jonathan Zimring’s Empirical Analysis
1999
Citation profile
296 federal appellate · 207 district · 86 state decisions
How this case has been cited
Cited by 1,099 later decisions (4 by the Supreme Court) — most recently May 2025 · most notably Tennessee v. Lane (2004), US Airways, Inc. v. Barnett (2002)
296 federal appellate · 207 district · 86 state decisions — followed in 19 states
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Appellate journey
reviewedL.C. ex rel. Zimring v. Olmstead (from Eleventh Circuit Court of Appeals)
Relationships
Applies 20 U.S.C. § 1400 (Education for All Handicapped Children Act of 1975) · 20 U.S.C. § 1681 (§ 901 of the Title IX of the Education Amendments of 1972) · 29 U.S.C. § 623 (§ 4 of the Age Discrimination in Employment Act of 1967) · 29 U.S.C. § 701 (Employment Opportunities for Individuals With Disabilities Act) · 29 U.S.C. § 794 · 29 U.S.C. § 794A · 42 U.S.C. § 12101 (§ 2 of the Americans with Disabilities Act of 1990) · 42 U.S.C. § 12116 (§ 106 of the Americans with Disabilities Act of 1990)
Relies on Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc. · Meritor Savings Bank, FSB v. Vinson · City of Cleburne Texas v. Cleburne Living Center · Skidmore v. Swift & Co. · Allen v. Wright
Cited together with Alexander v. Choate · Anderson v. Liberty Lobby, Inc. · Celotex Corporation v. Catrett H · Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc. · Tennessee v. Lane
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 1,099 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Sensibly construed, the fundamental-alteration component of the reasonable-modifications regulation would allow the State to show that, in the allocation of available resources, immediate relief for the plaintiffs would be inequitable, given the responsibility the State has undertaken for the care and treatment of a large and diverse population of persons with mental disabilities.”
84 later decisions quote this exact passage · from the majority“[a] public entity shall make reasonable modifications in policies, practices, or procedures when the modifications are necessary to avoid discrimination on the basis of disability, unless the public entity can demonstrate that making the modifications would fundamentally alter the nature of the service, program, or activity.”
30 later decisions quote this exact passage · from the majority“we confront the question whether the proscription of discrimination may require placement of persons with mental disabilities in community settings rather than in institutions.”
25 later decisions quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.