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Cite as: 541 U. S. 509 (2004) Opinion of the Court JUSTICE STEVENS delivered the opinion of the Court. Title II of the Americans with Disabilities Act of 1990 (ADA or Act), 104 Stat. 337, 42 U. S. C. §§ 12131-12165, provides that "no qualified individual with a disability shall, by reason of such disability, be excluded from participation in or be denied the benefits of the services, programs or activities of a public entity, or be subjected to discrimination by any such entity." § 12132. The question presented in this case is whether Title II exceeds Congress' power under § 5 of the Fourteenth Amendment. I In August 1998, respondents George Lane and Beverly Jones filed this action against the State of Tennessee and a number of Tennessee counties, alleging past and ongoing violations of Title II. Respondents, both of whom are paraplegics who use wheelchairs for mobility, claimed that they were denied access to, and the services of, the state court system by reason of their disabilities. Lane alleged that he was compelled to appear to answer a set of criminal charges on the second floor of a county courthouse that had no elevaeral of Delaware; for the State of Minnesota et al. by Mike Hatch, Attorney General of Minnesota, and Gary R. Cunninghamand Kristyn Anderson, Assistant Attorneys General, and by the Attorneys General for their respective States as follows: Richard Blumenthal of Connecticut, Lisa Madigan of Illinois, Thomas F Reilly of Massachusetts, Jeremiah W. (Jay)Nixon of Missouri, PatriciaA Madrid of New Mexico, Eliot Spitzer of New York, William H. Sorrell of Vermont, Christine 0. Gregoire of Washingtoh, and Peggy A. Lautenschlagerof Wisconsin; for the American Bar Association by Dennis W. Archer and Paul R. Q. Wolfson; for the Blanche Fischer Foundation by Sherril Nell Babcock; for the Lawyers' Committee for Civil Rights Under Law et al. by Charles Lester, Jr., Deborah M. Danzig, BarbaraR. Arnwine, Thomas J Henderson, Michael L. Foreman, Kristin M. Dadey, Vincent A. Eng, Dennis C. Hayes, Elliot Mincberg, and Michael Lieberman; for Paralyzed Veterans of America et al. by Timothy K. Armstrong, Elizabeth B. McCallum, Ira A. Burnim, and Jennifer Mathis; and for the Honorable Dick Thornburgh et al. by Arlene B. Mayerson, Claudia Center, and Elizabeth Kristen.

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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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Tennessee v. Lane

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