''Tennessee v. Lane'', 541 U.S. 509 (2004), was a case in the

Supreme Court of the United States The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...

involving Congress's enforcement powers under section 5 of the Fourteenth Amendment..

Background

The

plaintiff A plaintiff ( Π in legal shorthand) is the party who initiates a lawsuit (also known as an ''action'') before a court. By doing so, the plaintiff seeks a legal remedy. If this search is successful, the court will issue judgment in favor of the p ...

s were disabled Tennesseans who could not access the upper floors in state courthouses. They sued in federal court, arguing that since

Tennessee Tennessee ( , ), officially the State of Tennessee, is a landlocked state in the Southeastern region of the United States. Tennessee is the 36th-largest by area and the 15th-most populous of the 50 states. It is bordered by Kentucky to th ...

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 Disability is the experience of any condition that makes it more difficult for a person to do certain activities or have equitable access within a given society. Disabilities may be Cognitive disability, cognitive, Developmental disability, dev ...

; it allows those whose rights have been violated to sue states for

money damages At common law, damages are a remedy in the form of a monetary award to be paid to a claimant as compensation for loss or injury. To warrant the award, the claimant must show that a breach of duty has caused foreseeable loss. To be recognised at ...

. 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 Sovereign immunity, or crown immunity, is a legal doctrine whereby a sovereign or state cannot commit a legal wrong and is immune from civil suit or criminal prosecution, strictly speaking in modern texts in its own courts. A similar, stronger ...

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 ''City of Boerne v. Flores'', 521 U.S. 507 (1997), was a landmark decision of the Supreme Court of the United States concerning the scope of Congress's power of enforcement under Section 5 of the Fourteenth Amendment. The case also had a signific ...

'': 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

discrimination Discrimination is the act of making unjustified distinctions between people based on the groups, classes, or other categories to which they belong or are perceived to belong. People may be discriminated on the basis of race, gender, age, relig ...

on the basis of disability to justify the abrogation of sovereign immunity.

Opinion of the Court

In ''Lane'', the Supreme Court split 5–4. In the majority opinion written by Justice

John Paul Stevens John Paul Stevens (April 20, 1920 – July 16, 2019) was an American lawyer and jurist who served as an associate justice of the Supreme Court of the United States from 1975 to 2010. At the time of his retirement, he was the second-oldes ...

, the Court ruled that Congress did have enough evidence that the disabled were being denied those fundamental rights that are protected by the

Due Process Due process of law is application by state of all legal rules and principles pertaining to the case so all legal rights that are owed to the person are respected. Due process balances the power of law of the land and protects the individual pers ...

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. Chief Justice

William Rehnquist William Hubbs Rehnquist ( ; October 1, 1924 – September 3, 2005) was an American attorney and jurist who served on the U.S. Supreme Court for 33 years, first as an associate justice from 1972 to 1986 and then as the 16th chief justice from ...

and Associate Justices

Clarence Thomas Clarence Thomas (born June 23, 1948) is an American jurist who serves as an associate justice of the Supreme Court of the United States. He was nominated by President George H. W. Bush to succeed Thurgood Marshall and has served since 199 ...

and Antonin Scalia filed dissents.

References

External links

* {{DEFAULTSORT:Tennessee v. Lane United States disability case law United States Supreme Court cases United States Supreme Court cases of the Rehnquist Court United States Eleventh Amendment case law United States Fourteenth Amendment, section five case law 2004 in United States case law Courthouses in Tennessee

Background

Opinion of the Court

See also

References

External links