Home > Tennessee v. Lane

The plaintiffs were disabled Tennesseans who could not access the upper floors in state courthouses. They sued in federal court, arguing that since Tennessee was denying them public services because of their disabilities, it was violating Title II of the Americans with Disabilities Act (ADA). Under Title II, no one can be denied access to public services due to his or her disability; it allows those whose rights have been violated to sue states for money damages.

Tennessee argued that the Eleventh Amendment prohibited the suit, and filed a motion to dismiss the case. It relied principally on Board of Trustees of the University of Alabama v. Garrett (2001), in which the Supreme Court held that Congress had, in enacting certain provisions of the ADA, unconstitutionally abrogated the sovereign immunity of the states by letting people sue the states for discrimination on the basis of disability. That case, in turn, relied on the rule laid down by City of Boerne v. Flores: Congress may abrogate the Eleventh Amendment using its section 5 powers only if the way it seeks to remedy discrimination is "congruent and proportional" to the discrimination itself. Garrett had held that Congress had not met the congruent-and-proportional test—i.e., that it had not amassed enough evidence of disability discrimination to justify the abrogation of sovereign immunity.

In Lane, the Supreme Court split 5-4. In an opinion written by Justice John Paul Stevens, the majority ruled that Congress did have enough evidence that the disabledAmericans with disabilities are one of the largest minority groups in the United States. According to the , approximately 20% of Americans are disabled. This percentage varies depending on how disabilities are defined. According to , "About 1 in 5 America were being denied those fundamental rights that are protected by the Due ProcessDue process of law is a legal concept that ensures the government will respect all of a person's legal rights instead of just some or most of those legal rights, when the government deprives a person of life, liberty, or property. Due process has also bee clause of the Fourteenth Amendment, among those rights being the right to access a court. Further, the remedy Congress enacted was congruent and proportional, because the "reasonable accommodations" mandated by the ADA were not unduly burdensome and disproportionate to the harm. Garrett, the Court said, applied only to Equal Protection claims, not to Due Process claims. Therefore the law was constitutional. Justices William RehnquistChief Justice of the United States since 1986. William Hubbs Rehnquist (born October 1, 1924) is an American jurist. He is a former law clerk and Assistant Attorney General and has served as the 16th Chief Justice of the United States since he was elevate and Antonin ScaliaAntonin Scalia (born March 11, 1936) has been a US Supreme Court Associate Justice since 1986. He is widely considered the leading conservative voice on the Court. Antonin Scalia was born in Trenton, New Jersey. His mother, Catherine, was born in the Unit filed dissents.