1. Olmstead v. L.C., 527 U.S. 581 (1999)
Two women “voluntarily” entered a state hospital for individuals with cognitive impairments (mental retardation and/or mental illness) to receive treatment.
They were declared “fit” to return to community, were not allowed to leave because the state declared there were no appropriate supports available for them in the community.
They sued the state arguing that Title II of the ADA prohibits a public entity from discriminating against qualified persons with disabilities.
The term "discrimination" includes the failure of a public entity to administer its programs in the most integrated setting appropriate to the needs of qualified individuals with disabilities.
Further, a public entity must make reasonable modifications to it policies and practices unless such measures would fundamentally alter the nature of the public entity's program.

2. Olmstead Issue:
Does the nondiscrimination mandate (under Title II) require placement of persons with disabilities in community settings rather than in institutions in certain circumstances, in order to achieve the "integration" requirement?

3. Olmstead Holding/Ruling:
Qualified YES. Unnecessary institutionalization violates civil rights of people with disabilities
States are required to make reasonable modifications in order to serve people in the community when:
The individual desires to live in a community setting;
The state’s treatment professionals determine community placement is appropriate; and
The placement can be reasonably accommodated, considering the resources available to the state and the needs of others receiving services from the state.

4. Olmstead Reasoning:
Supremes show deference to Department of Justice regulations: 1) unjustified placement or retention of persons in institutions constitutes discrimination “by reason of disability” under Title II and 2) reasonable modifications to programs/services required.
Looks to purpose behind ADA passage and statutory language.
Modifies the Court of Appeals construction of “reasonable modification” regulation to provide State some defense to obligation to immediately find placements in the community.
Opines that states have obligation to administer services “with an even hand” and may consider resources available and the range of services required for others in State.