Tennessee v. Lane
Headline: Courthouse access ruling upholds Title II of the ADA, allowing disabled people to sue states for money damages when lack of physical access blocks their right to participate in court proceedings.
Holding: The Court held that Title II of the ADA validly enforces the Fourteenth Amendment and permits private money-damage suits against States when lack of courthouse access denies people their right to participate in court.
- Allows disabled people to sue states for money damages when courthouse access denies participation.
- Requires courts and local governments to make reasonable accessibility modifications.
- Does not force fundamental service changes and allows defenses for undue burden.
Summary
Background
Two Tennessee residents who use wheelchairs sued the State and several counties after they say courthouse buildings and court procedures blocked their ability to take part in court. One man crawled up stairs to attend an initial hearing and was later jailed after refusing to be carried to a second hearing; a certified court reporter said inaccessible courthouses cost her work and the chance to participate. The State argued it was protected by the Eleventh Amendment from private money-damage suits. Lower courts considered earlier decisions, including this Court’s Garrett decision about the ADA, and the case was sent back for review before reaching this Court.
Reasoning
The Court asked whether Congress validly used its power under the Fourteenth Amendment to allow private money-damage suits against States under Title II of the ADA. It found Congress clearly expressed its intent to override state immunity and relied on a large legislative record showing widespread exclusion of disabled people from public services, including many inaccessible state buildings and courthouses. Applying the Court’s test for §5 laws (congruence and proportionality), the majority concluded Title II is a reasonable, limited response as applied to cases about access to courts. Title II requires reasonable modifications, allows alternatives like service relocation or assistance for older buildings, and protects States from measures that cause undue burdens, historic-preservation harms, or fundamental alterations.
Real world impact
As a result, people denied meaningful access to judicial proceedings because of physical or similar barriers can press money-damage claims against States under Title II in the courthouse-access context. The decision pushes states and local governments to take reasonable steps to make court services accessible, but does not require limitless changes and leaves some defenses available to governments.
Dissents or concurrances
Several Justices concurred in the judgment but stressed limits on the Court’s tests. The Chief Justice and other dissenters argued the record did not show a pattern of constitutional violations by States and that allowing broad money-damage suits improperly rewrites the Fourteenth Amendment’s enforcement power.
Opinions in this case:
Ask about this case
Ask questions about the entire case, including all opinions (majority, concurrences, dissents).
What was the Court's main decision and reasoning?
How did the dissenting opinions differ from the majority?
What are the practical implications of this ruling?