Eleventh Circuit: Florida, Georgia & Alabama
Verified September 2026.
The Eleventh Circuit (Florida, Georgia, Alabama) has demonstrated moderate to active Olmstead enforcement focused on nursing facility reliance, state psychiatric hospitals, school segregation, and specialized populations like children with complex medical needs. The circuit encompasses cases ranging from completed settlement monitoring to newly emergent litigation on medically fragile children.
Florida: United States v. Florida — Children with Medical Complexity
Case Name: United States v. Florida, 1:13-cv-61576 (S.D. Fla.)
Case Resources:
- Google Scholar Case Search
- PACER Federal Court Records (1:13-cv-61576)
- Disability Rights Florida (P&A)
The Issue: Children with significant medical needs unnecessarily placed in nursing facilities despite the ability to serve them at home with appropriate supports. The DOJ alleged that Florida’s Medicaid policies effectively segregate medically fragile children who could be served at home with adequate supports.
Federal Court Ruling (2023): Federal judge ruled that Florida violated the rights of children with complex medical needs. The Department of Health and Human Services supported the ruling.
Current Status: Ongoing federal enforcement. Disputes continue over Medicaid policy changes affecting medically fragile children’s access to home and community-based care.
Significance: This case is a critical test of Olmstead enforcement for medically complex children—a population often overlooked in broader deinstitutionalization efforts. Federal enforcement in this case affects national Medicaid policy on pediatric home-based care.
Related Cases: Lee v. Dudek, Cruz v. Dudek, Haddad v. Arnold, Jones v. Arnold, Long v. Benson, Alvey v. Gualtieri
Georgia: U.S. v. Georgia — Psychiatric Hospitals and School Segregation
Case 1: U.S. v. Georgia (Psychiatric Hospitals)
Case Name: U.S. v. Georgia, 10-cv-249 (N.D. Ga.)
Case Resources:
The Issue: State psychiatric hospitals and community integration for individuals with serious mental illness. Extensive DOJ findings on segregation and inadequate community mental health services.
Case 2: U.S. v. Georgia — School Segregation (GNETS Program)
DOJ Findings Letter: July 15, 2015
Case Resources:
The Issue: Students with behavior-related disabilities segregated in GNETS (Georgia Network for Educational and Therapeutic Support) centers. DOJ findings letter requiring Georgia to integrate students into mainstream educational settings.
Related Litigation: Hunter v. Cook, Georgia Advocacy Office v. Shelp, Knipp v. Perdue — Additional challenges to institutional conditions and segregation.
Current Status (2026): Georgia’s Department of Behavioral Health and Developmental Disabilities (DBHDD) requested release from federal oversight of the U.S. v. Georgia (2010) settlement in January 2026, claiming substantial compliance. However, the DOJ and disability advocates contested the request. Georgia simultaneously announced plans to build a new forensic mental health hospital—the first state psychiatric hospital since the original Olmstead case—a decision that has drawn criticism from disability rights organizations as potentially counterproductive to integration goals.
Significance: Georgia’s ongoing litigation, combined with the state’s announcement of new psychiatric hospital construction, positions Georgia as a critical case study in the tension between federal integration mandates and state policy direction.
Alabama: Boyd v. Mullins — Nursing Facility Reliance
Case Name: Boyd v. Mullins, 2:10-cv-688 (M.D. Ala.)
Case Resources:
- Google Scholar Case Search
- PACER Federal Court Records (2:10-cv-688)
- Alabama Disabilities Advocacy Program (ADAP – P&A)
The Issue: A man with quadriplegia living in a nursing home alleged that the state administered Medicaid so as to force his institutionalization despite his ability to live in the community with adequate supports.
Status: No comprehensive statewide settlement has been reached, but the case remains active in federal court.
Related Case: Alabama Disabilities Advocacy Program v. SafetyNet Youthcare, 2:13-cv-00519 (S.D. Ala.)—A facility’s refusal to grant the P&A access to residents, raising foundational questions about oversight authority.
SCII Finding (2026): Alabama is still auditing settings under the CMS HCBS Settings Rule that function institutionally despite carrying a community classification. This suggests ongoing compliance gaps even in nominally community-based settings.
Eleventh Circuit Enforcement Pattern
The Eleventh Circuit has shown willingness to find Olmstead violations across multiple domains: psychiatric hospitalization, school segregation, nursing facility reliance, and, more recently, Medicaid policies affecting access to home-based care for medically complex children. Cases in this circuit range from foundational psychiatric hospital cases to emerging litigation on specialized populations.
Key Takeaway: Eleventh Circuit courts recognize that Olmstead violations occur through multiple pathways—not just institutional operation, but also through Medicaid policies, educational system practices, and structural barriers to accessing community-based alternatives. The circuit’s attention to medically complex children represents an emerging frontier in Olmstead enforcement.