Tennessee v. Lane

541 U.S. 509 (2004)

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Nature of the Case

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Facts

George Lane and Beverly Jones (P) filed this action against the State of Tennessee (D). Ps were paraplegics who use wheelchairs for mobility. Ps claimed they were denied access to, and the services of, the state court system by reason of their disabilities. At P's first appearance on a criminal charge, P crawled up two flights of stairs to get to the courtroom. Upon returning for a hearing, P refused to crawl again or to be carried by officers to the courtroom. P 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. Ps sought damages and equitable relief. D moved to dismiss on 11th Amendment grounds. The District Court denied the motion without opinion, and D appealed. The United States intervened to defend Title II's abrogation of the States' Eleventh Amendment immunity. The Sixth Circuit entered an order holding the case in abeyance pending the decision in Board of Trustees of Univ. of Ala. v. Garrett, 531 U. S. 356 (2001). Garrett concluded that the Eleventh Amendment bars private suits seeking money damages for state violations of Title I of the ADA. The majority of the Sixth Circuit interpreted Garrett to bar private ADA suits against States based on equal protection principles, but not those that rely on due process principles. A panel of the Court of Appeals entered an order affirming the District Court's denial of D's motion to dismiss in this case. The order explained that Ps' claims were not barred because they were based on due process principles. The Due Process Clause protects the right of access to the courts, and that the evidence before Congress when it enacted Title II 'established that physical barriers in government buildings, including courthouses and in the courtrooms themselves, have had the effect of denying disabled people the opportunity to access vital services and to exercise fundamental rights guaranteed by the Due Process Clause. The Supreme Court granted certiorari.