Tennessee v. Lane

PETITIONER: Tennessee
RESPONDENT: George Lane, et al.
LOCATION: Polk County Courthouse

DOCKET NO.: 02-1667
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Sixth Circuit

CITATION: 541 US 509 (2004)
GRANTED: Jun 23, 2003
ARGUED: Jan 13, 2004
DECIDED: May 17, 2004

ADVOCATES:
Michael E. Moore - argued the cause for Petitioner
Paul D. Clement - argued the cause for Respondent United States
William J. Brown - argued the cause for Respondents Lane and Jones

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.

Question

Did the Americans with Disabilities Act violate the sovereign immunity doctrine of the 11th Amendment when, based on Congress's 14th Amendment enforcement powers of the Due Process clause, it allowed individuals to sue states for denying them services based on their disabilities?

Media for Tennessee v. Lane

Audio Transcription for Oral Argument - January 13, 2004 in Tennessee v. Lane

Audio Transcription for Opinion Announcement - May 17, 2004 in Tennessee v. Lane

John Paul Stevens:

The second case I have to announce is Tennessee against Lane.

Respondents are paraplegics who use wheelchairs for mobility.

They claim that the State of Tennessee has failed to provide them with reasonable access to several County courthouses.

They have filed suit against the State and a number of its counties pursuant to Title II of the American with Disabilities Act, which forbids public entities from discriminating against persons with disabilities in the administration of public services.

They sought both money damages and equitable relief.

The State moved to dismiss the suit invoking the State’s Eleventh Amendment immunity from private suits for money damages.

The District Court denied the motion.

While the case was pending on appeal, this Court issued its decision in Board of Trustees of the University of Alabama against Garrett which held that the Eleventh Amendment bars private suits for money damages under Title I of the ADA, the Title that prohibits employment discrimination against the disabled.

Garrett left opened the question whether suits for money damages are permitted under Title II.

In answering that question in this case, the Sixth Circuit held that the Eleventh Amendment did not bar respondent’s suit.

We granted certiorari and now affirm.

It is well settled that Congress can abrogate Eleventh Amendment immunity when it acts pursuant to its authority under Section 5 of the Fourteenth Amendment to enforce the substantive guarantees of that Amendment.

The primary question in this case is whether Title II constitutes a valid exercise of Congress Section 5 power.

In Garrett, we held that Title I was not a valid section five enforcement legislation because its broad remedial scheme was insufficiently targeted to remedy or prevent constitutional violations.

We concluded that disability based classification are valid under the Fourteenth Amendment if they bare a rational relationship to a legitimate government purpose and if the states were not engaging in a pattern of irrational employment discrimination against the disabled.

Title II differs from Title I in several respects.

Whereas Title I aims primarily at employment discrimination in the private sector, Title II aims that the whole range of public services in the public sector.

Most important, it seeks to enforce not only the constitutional prohibition on an irrational discrimination but also a number of other fundamental constitutional rights.

Infringements of these rights, including the right of access to the courts, that is at issue in this case, are subject to a heightened standard of judicial review.

Moreover, Congress had ample reason to think that legislative action was needed to remedy or prevent violation of these rights.

Judicial decisions, the legislative records, congressional hearing testimony, and anecdotal evidence, all describe a pattern of pervasive unequal treatment of the disabled in the administration of public services and programs including the systematic deprivation of fundamental constitutional rights.

The question then is whether Title II is, in the language of this Court’s Section 5 cases, a congruent and proportional response to this pattern of discriminatory treatment.

Title II, unlike other statutes we have reviewed for validity under Section five, does not seek to enforce just one constitutional provision but reaches a wide array of official conduct in an effort to enforce an equally wide array of constitutional rights.

We therefore go no further than the precise question that this case presents.

Whether Title II appropriately enforces the constitutional right have access to the court?

We hold that it does.

Title II requires public entities to make reasonable modifications to permit persons with disabilities to participate in judicial proceedings.

This duty to make reasonable accommodations is perfectly consistent with the well-establish principle that states must afford all individuals a meaningful right to be heard in court.

So, the judgment of the Court of Appeals is affirmed.

Justice Souter has filed a concurring opinion in which Justice Ginsburg joined: Justice Ginsburg has also filed a concurring opinion in which Justice Souter and Justice Breyer joined; The Chief Justice has filed a dissenting opinion which Justice Kennedy and Justice Thomas joined; Justice Scalia and Justice Thomas have also filed dissenting opinions.