Tennessee v. Lane
Tennessee v. Lane | |
---|---|
Holding | |
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. | |
Court membership | |
| |
Case opinions | |
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 |
Dissent | Scalia |
Dissent | Thomas |
Tennessee v. Lane, 541 U.S. 509 (2004), was a case in the Supreme Court of the United States involving Congress's enforcement powers under section 5 of the Fourteenth Amendment.[1]
Background
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.
Opinion of the Court
In Lane, the Supreme Court split 5–4. In the majority opinion written by Justice
See also
- List of United States Supreme Court cases, volume 541
- List of United States Supreme Court cases by the Rehnquist Court
References
External links
- Text of Tennessee v. Lane, 541 U.S. 509 (2004) is available from: Cornell Findlaw Justia Library of Congress Oyez (oral argument audio)