Southeastern Community College v. Davis

Facts of the Case

The dispute arose when Francis B. Davis sought to enroll in the nursing program offered by Southeastern Community College. When school officials determined Davis had a severe hearing loss, they denied her request for admission. Officials reasoned that Davis's hearing loss made it impossible for her to complete the clinical portion of the program in a manner that was safe for patients. Moreover, insofar as Davis was unable to satisfy this requirement, officials were convinced that she could not reasonably have been adequately prepared to function in a professional nursing capacity. College officials considered modifications that might have allowed her to participate, but decided that making those accommodations would have altered the program to the extent that it would no longer have been beneficial to Davis.

Davis sued the college, alleging that officials only needed to have made reasonable accommodations for her hearing loss in order to avoid discriminating against her under Section 504. A federal trial court entered a judgment in favor of the college, but the Fourth Circuit reversed in favor of Davis.

The Court's Ruling

On further review, Justice Powell wrote the opinion for a unanimous Supreme Court that reversed in favor of the college. At issue was whether Davis was “otherwise qualified” for admission to the nursing program and if so, what “reasonable accommodations” the college was required to make in order to treat her in a manner comparable to that of her peers who were not disabled. After examining both the statute and its regulations, the Court, in an initial matter, ruled that “an otherwise qualified person is one who is able to meet all of a program's requirements in spite of his handicap” (p. 406)

The Supreme Court then turned to whether Davis could meet the requirements of the program with reasonable accommodations. The Court noted that [Page 776]the physical requirements of the course of study were adopted without any animus toward Davis or persons with disabilities generally. Rather, the Court pointed out that completion of the program required candidates to have the ability to understand and quickly react to spoken language when a speaker's face was unavailable for speech reading. While Davis was able to complete some tasks associated with nursing, the record reflected that she could not accomplish the goals of the college's program without substantial modifications. The Court was of the opinion that the accommodations contemplated by the regulations of Section 504 did not require officials to modify the program substantially. Accordingly, the Court concluded that because officials did not discriminate against Davis, they were under no obligations to make the modifications that she requested.

...