Tennessee v. Lane
|Tennessee v. Lane|
|Argued January 13, 2004
Decided May 17, 2004
|Full case name||Tennessee, Petitioner v. George Lane et al.|
|Citations||541 U.S. 509 (more)|
|Congress has the power under Section 5 of the Fourteenth Amendment to abrogate the States' sovereign immunity in cases implicating the fundamental right of access to the courts.|
|Majority||Stevens, joined by O'Connor, Souter, Ginsburg, Breyer|
|Concurrence||Souter, joined by Ginsburg|
|Concurrence||Ginsburg, joined by Souter, Breyer|
|Dissent||Rehnquist, joined by Kennedy, Thomas|
The plaintiffs were disabled Tennesseans who could not access the upper floors in state courthouses. They sued in Federal Court, arguing that since Tennessee 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; it allows those whose rights have been violated to sue states for money damages.
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 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: 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 on the basis of disability to justify the abrogation of sovereign immunity.
In Lane, the Supreme Court split 5-4. In an opinion written by Justice John Paul Stevens, the majority ruled that Congress did have enough evidence that the disabled were being denied those fundamental rights that are protected by the Due Process 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, and Associate Justices Clarence Thomas, and Antonin Scalia filed dissents.
Note: An important distinguishing feature that Lane proposes is that the Court utilized an "as applied" feature, analyzing the statute in question 'as applied' to the facts of the claim. This 'as applied' function is a great shift in the 'congruent and proportionality' test the Court administers to ensure that Congress has not exceeded its section 5 powers (which can only be used to remedy or prevent one of the civil rights amendment's violations - 13th, 14th and 15th amendments). Here, the statute was the ADA which prevents a disabled person from being denied public access, public access in this case being court houses ('as applied' function in effect). Reasonable accommodations, such as an elevator, was required by the plaintiffs (disabled plaintiffs) to acquire access to the court house's second floor. The remedy requested was not unduly burdensome and therefore 'congruent and proportional' to the harm intended to be remedied by the ADA. Thus, this 'as applied' analysis does not consider the statute in the aggregate to be applied to all public services, such as government-owned hockey rinks, but simply the facts in question. Due to this 'as applied' function, Congress apparently[original research?] has a greater chance of having its federal statutes survive attacks by States who claim the Eleventh Amendment (i.e., their state-sovereign immunity privilege) and argue the statute should be invalidated because it is unconstitutional. Lastly, this 'as applied' function appears to apply, arguably, only when there is a Due Process claim as opposed to an Equal Protection claim.
- ^ 541 U.S. 509 Full text of the opinion from Cornell University Law School.
- Summary of case from OYEZ
- 541 U.S. 509 Full text of the opinion courtesy of Findlaw.com.