Why is the case important?
George Lane (P) and Beverly Jones (P) both used wheelchairs. They were not able to enter several courthouses because of non-availability of wheelchair entrances. They sued Tennessee (D) on the ground of Title II of the Americans with Disabilities Act of 1990 (ADA). Tennessee (D) argued that the law was unconstitutional.
Facts of the case
“George Lane and Beverly Jones were disabled and could not access upper floors in Tennessee state courthouses. Lane, Jones, and several others sued Tennessee in federal district court, alleging that by denying them public services based on their disabilities, Tennessee was in violation of Title II of the Americans with Disabilities Act (1990). According to Title II, no person may be denied access to “”services, programs, or activities”” on the basis of his disability. The act allows alleged victims of discrimination to sue states for damages.Tennessee asked that the case be dismissed, claiming that it was barred by the 11th Amendment’s prohibition of suits against states in federal courts (the sovereign immunity doctrine). The state cited Alabama v. Garrett (2001), in which the U.S. Supreme Court ruled that Congress had acted unconstitutionally in granting citizens the right to sue states for disability discrimination (such as the denial of employment) under the 14th Amendment’s equal protection clause. In that case the Supreme Court reasoned that Congress did not have enough evidence of disability discrimination by states to justify the waiver of sovereign immunity.The district court rejected the state’s argument and denied the motion to dismiss. The Sixth Circuit Court of Appeals panel affirmed. The courts reasoned that because Title II of the ADA dealt with the Due process Clause of the 14th Amendment, not the equal protection clause, the ruling in Garrett did not apply. The court found that while Congress may not have had enough evidence of disability discrimination to waive sovereign immunity for equal protection claims, it did have enough evidence of Due Process violations (such as non-handicap-accessible courthouses) to waive the sovereign immunity doctrine for Due Process claims.”
Is Title II of the ADA constitutional in prohibiting discrimination against disabled persons by public entities?
(Stevens, J.) Yes. Title II of the ADA which prevents discrimination against disabled persons by public entities is constitutional. It makes provision for disabled persons to be able to participate in or take part in the benefits of any service, program or activity conducted by a public body without discrimination because of their disability. This title was enacted because of a systematic and widespread system of discrimination against disabled persons in state services and programs, whether public education, the penal system or the voting system. This discrimination amounted in many cases to depriving disabled persons of their fundamental rights. This is so in the present case as well. The evidence before Congress shows that many disabled persons in many states were denied the opportunity to take part in courthouses or court proceedings because of their medical condition. Three-fourths of all public services or programs operating from premises owned by the state and therefore under its control were not made accessible to these persons, and were hence not available for their use. The record shows that the list of these violations is far greater than many other types of constitutional violations in which this Court has awarded damages as a fitting remedy. Congress has the authority to enforce the right guaranteed under the constitution, of having access to the courts. The way it has chosen to enforce this right, through Title II of the ADA, and to provide remedy for the present case of exclusion from the exercise of a fundamental right and of discrimination against disability, is both fitting and proportional in regard to its aim. The decision of the lower court is affirmed.
The United States Supreme Court held, however, that Title II, as it applied to the class of cases implicating the fundamental right of access to the courts, constituted a valid exercise of Congress’s authority. Title II was responsive to evidence of pervasive unequal treatment of persons with disabilities in the administration of state services and programs, and such disability discrimination was thus an appropriate subject for prophylactic legislation. Regardless of whether the State could be subjected to liability for failing to provide access to other facilities or services, the fundamental right of access to the courts warranted the limited requirement that the State reasonably accommodate disabled persons to provide such access. Title II was thus a reasonable prophylactic measure, reasonably targeted to a legitimate end.
- Case Brief: 2004
- Petitioner: Tennessee
- Respondent: George Lane, et al.
- Decided by: Rehnquist Court
Citation: 541 US 509 (2004)
Granted Jun 23, 2003
Argued: Jan 13, 2004
Decided: May 17, 2004