---
title: HR 54. United States Supreme Court's Olmstead decision and the courage of its plaintiffs; honor anniversary
collection: bills
id: 2026-special/hr54
cite_as: HR 54, 2026 Special Session (Ga.)
canonical_url: https://georgiacommons.org/bills/2026-special/hr54
md_url: https://georgiacommons.org/bills/2026-special/hr54.md
text_url: https://georgiacommons.org/bills/2026-special/hr54/text
source_url: https://www.legis.ga.gov/legislation/74915
date: 2026-06-23
status: passed
corpus_version: bills-2026-09-13
license: Public record of the Georgia General Assembly, via LegiScan; see about.md
publisher: Georgia Commons, an independent project of Georgia Civic Data. Not the State of Georgia. Not legal advice.
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next: https://georgiacommons.org/bills/2026-special/hr55.md
index: https://georgiacommons.org/bills/index.md
omitted: votes and history
omitted_chars: 131
omitted_url: https://georgiacommons.org/bills/2026-special/hr54.md?full=1
bill_number: HR 54
session: 2026 Special Session
session_slug: 2026-special
chamber: House
bill_type: resolution
status_date: 2026-06-23
last_action: House Read and Adopted
sponsors:
  - Gabriel Sanchez
  - Eric Gisler
  - Bryce Berry
  - Long Tran
  - Karla Drenner
  - Jasmine Clark
text_version: Introduced
has_text: true
legiscan_url: https://legiscan.com/GA/bill/HR54/2026/X1
upstream_id: 2154550
summaries_model: claude-sonnet-5
topic_tags:
  - disability rights
  - Olmstead decision
  - mental health policy
  - deinstitutionalization
---

# HR 54. United States Supreme Court's Olmstead decision and the courage of its plaintiffs; honor anniversary

## Text

House Resolution 54EX
By: Representatives Sanchez of the 42nd, Gisler of the 121st, Berry of the 56th, Tran of the
80th, Drenner of the 85th, and others
A RESOLUTION
Honoring the anniversary of the Unites States Supreme Court's Olmstead decision and the
courage of its plaintiffs; and for other purposes.
WHEREAS, the United States Supreme Court decided in Olmstead v. L.C., 527 U.S. 581
(1999), that states are required to place individuals with mental disabilities in community
settings, rather than institutions, when treatment professionals determine such placement is
appropriate, the individual consents, and such placement can reasonably be accommodated;
and
WHEREAS, as a result of the decision, the State of Georgia released lead plaintiff Lois
Curtis into community care, and she lived happily for over 20 years outside of institutional
confinement; and
WHEREAS, June 22, 2026, will be the 27th anniversary of the Olmstead decision; and
WHEREAS, the State of Georgia is currently working to improve compliance with the
Olmstead decision pursuant to a consent decree with the United States Department of Justice;
and
H. R. 54EX
WHEREAS, fellow plaintiff Elaine Wilson passed away on December 4, 2005; and
WHEREAS, Lois Curtis passed away on November 3, 2022, from pancreatic cancer; and
WHEREAS, the advocacy of Lois Curtis and Elaine Wilson secured an important legal
standard for enforcing the rights of individuals with mental disabilities; and
WHEREAS, on June 18, 2026, the United States Department of Justice released a memo
claiming that the Olmstead decision has increased homelessness and does not impose an
integration mandate; and
WHEREAS, the members of this body wish to express the strongest disapproval of this
memo, which legal experts do not believe to be enforceable.
NOW, THEREFORE, BE IT RESOLVED BY THE HOUSE OF REPRESENTATIVES that
the members of this body honor the courage and memory of Lois Curtis and Elaine Wilson.
BE IT FURTHER RESOLVED that the members of this body express their continued will
to improve disability rights in Georgia in accordance with the Olmstead decision.
BE IT FURTHER RESOLVED that the members of this body condemn attacks on the
Olmstead decision and the framework it lays out for improving disability rights.
BE IT FURTHER RESOLVED that the Clerk of the House of Representatives is authorized
and directed to make appropriate copies of this resolution available for distribution to the
public and the press.
H. R. 54EX

## Summaries written by Georgia Commons

The following was written by claude-sonnet-5 from the text above and is not part of the resolution. Quote the text, not the summary.

A Georgia House resolution honors the 27th anniversary of the U.S. Supreme Court's Olmstead decision and the plaintiffs who won it, while criticizing a recent federal memo that questions the ruling's reach.

### Plain-language summary

This resolution marks the anniversary of Olmstead v. L.C., the 1999 U.S. Supreme Court case that said states must place people with mental disabilities in community settings instead of institutions when doctors agree it is appropriate, the person consents, and it can reasonably be arranged. It recalls lead plaintiff Lois Curtis, who was released into community care and lived outside institutions for over 20 years before her death in 2022, and fellow plaintiff Elaine Wilson, who died in 2005.
The resolution notes that Georgia is still working to comply with the decision under a consent decree with the U.S. Department of Justice. It also responds to a June 18, 2026 Justice Department memo that claims the Olmstead ruling increased homelessness and does not require integration. The Georgia House formally honors the plaintiffs, reaffirms its commitment to disability rights, and condemns the memo and other challenges to the Olmstead framework.

### What it does

- Honors the courage and memory of Olmstead plaintiffs Lois Curtis and Elaine Wilson.
- States the Georgia House's continued commitment to improving disability rights in line with the Olmstead decision.
- Formally condemns a June 2026 U.S. Department of Justice memo and other attacks on the Olmstead framework.
- Directs the Clerk of the House to distribute copies of the resolution to the public and press.

### Who it affects

The resolution most directly concerns people with mental disabilities in Georgia who rely on community-based care rather than institutional placement, as well as state agencies working under the federal consent decree tied to Olmstead compliance and disability rights advocates.

### Why it matters

While a resolution carries no legal force, it signals the Georgia House's stance in favor of maintaining Olmstead's community-placement standard at a moment when a federal memo has questioned that standard, potentially shaping future state disability policy debates.

### Key provisions

- The resolution recites the history of Olmstead v. L.C., 527 U.S. 581 (1999), and its requirement that states use community placement over institutionalization when appropriate.
- It references Georgia's ongoing consent decree with the U.S. Department of Justice to improve Olmstead compliance.
- It notes a June 18, 2026 Justice Department memo claiming Olmstead increased homelessness and lacks an integration mandate.
- The resolved clauses honor plaintiffs Lois Curtis and Elaine Wilson, reaffirm commitment to disability rights, and condemn the memo and other attacks on the decision.
- The final clause directs the House Clerk to make copies available to the public and press.

## Status

- Status: Passed (2026-06-23)
- Last action: House Read and Adopted (2026-06-23)
- Sponsors: Gabriel Sanchez, Eric Gisler, Bryce Berry, Long Tran, Karla Drenner, Jasmine Clark
- Official page: https://www.legis.ga.gov/legislation/74915

> The history, votes, and amendments (131 characters) are at https://georgiacommons.org/bills/2026-special/hr54.md?full=1
