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TENNESSEE v. LANE Opinion of the Court tor. At his first appearance, Lane crawled up two flights of stairs to get to the courtroom. When Lane returned to the courthouse for a hearing, he refused to crawl again or to be carried by officers to the courtroom; he consequently was arrested and jailed for failure to appear. Jones, a certified court reporter, alleged that she has not been able to gain access to a number of county courthouses, and, as a result, has lost both work and an opportunity to participate in the judicial process. Respondents sought damages and equitable relief. The State moved to dismiss the suit on the ground that it was barred by the Eleventh Amendment. The District Court denied the motion without opinion, and the State appealed. 1 The United States intervened to defend Title II's abrogation of the States' Eleventh Amendment immunity. On April 28, 2000, after the appeal had been briefed and argued, the Court of Appeals for the Sixth Circuit entered an order holding the case in abeyance pending our decision in Board of Trustees of Univ. of Ala. v. Garrett,531 U. S. 356 (2001). In Garrett, we concluded that the Eleventh Amendment bars private suits seeking money damages for state violations of Title I of the ADA. We left open, however, the question whether the Eleventh Amendment permits suits for money damages under Title II. Id., at 360, n. 1. Following the Garrett decision, the Court of Appeals, sitting en banc, heard argument in a Title II suit brought by a hearingimpaired litigant who sought money damages for the State's failure to accommodate his disability in a child custody proceeding. Popovich v. CuyahogaCounty Court, 276 F. 3d 808 (CA6 2002). A divided court permitted the suit to proceed 'In Puerto Rico Aqueduct and Sewer Authority v. Metcalf & Eddy, Inc., 506 U. S. 139 (1993), we held that "States and state entities that claim to be 'arms of the State' may take advantage of the collateral order doctrine to appeal a district court order denying a claim of Eleventh Amendment immunity." Id., at 147.

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Tennessee v. Lane

Judgment

Question Presented: Whether Title II of the Americans with Disabilities Act validly abrogates state sovereign immunity under the 11th Amendment and whether people with disabilities have a right to access courts to lodge fundamental rights claims, including electoral disputes.

Alleged Acts: A paraplegic who used a wheelchair, Lane, in 1996 was summoned to appear at the Polk County Courthouse in Tennessee as a criminal defendant. The courthouse had no elevator, and Lane could not access the second-floor courtroom. He was forced to crawl up two flights of stairs to reach the courtroom for his own criminal hearing. When he returned for a subsequent hearing, he refused to crawl up the stairs and was arrested and jailed for failure to appear.

Procedural history: District court ruled that Congress validly abrogated state sovereign immunity against Title II in Americans with Disabilities Act, dismissing Tennessee's Motion to Dismiss. The Sixth Circuit Court of Appeals affirmed the District Court's ruling.

Summary: Tennessee v. Lane, 541 U.S. 509 (2004) is a U.S. Supreme Court case that addressed whether Congress could validly abrogate a state’s Eleventh Amendment sovereign immunity under the Fourteenth Amendment to enforce access to courts for people with disabilities.

Conclusion: Title II of the Americans with Disabilities Act, as applied to the class of cases implicating the fundamental right of access to the courts, constitutes a valid exercise of Congress's Section 5 authority to enforce the guarantees of the Fourteenth Amendment.

Legal Issue(s)

Criminal Procedure
Elections as a Fundamental Right

Applicable Law(s): Americans with Disabilities Act, Eleventh Amendment, and Fourteenth Amendment of the United States Constitution

Region: Americas

Country: United States of America

Language of Decision

English

Court: Supreme Court

Election Type: General

Date of decision: May 17, 2004

Geolocation

Latitude: 38.8906

Longitude: -77.0047

: Geolocation

Link: https://tile.loc.gov/storage-services/service/ll/usrep/usrep541/usrep541509/usrep541509.pdf

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Tennessee v. Lane.pdf
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Election Judgments - IFES

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Tennessee v. Lane

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