Tennessee v. Lane
Encyclopedia
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
.
The plaintiff
s 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 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.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(2004), was a case in the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
involving Congress's
United States Congress
The United States Congress is the bicameral legislature of the federal government of the United States, consisting of the Senate and the House of Representatives. The Congress meets in the United States Capitol in Washington, D.C....
enforcement powers
Congressional power of enforcement
A Congressional power of enforcement is included in a number of amendments to the United States Constitution. The language "The Congress shall have power to enforce this article by appropriate legislation" is used, with slight variations, in Amendments XIII, XIV, XV, XVIII, XIX, XXIII, XXIV, and XXVI...
under section 5 of the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
.
The plaintiff
Plaintiff
A plaintiff , also known as a claimant or complainant, is the term used in some jurisdictions for the party who initiates a lawsuit before a court...
s were disabled Tennesseans who could not access the upper floors in state courthouses. They sued in Federal Court, arguing that since Tennessee
Tennessee
Tennessee is a U.S. state located in the Southeastern United States. It has a population of 6,346,105, making it the nation's 17th-largest state by population, and covers , making it the 36th-largest by total land area...
was denying them public services because of their disabilities, it was violating Title II of the Americans with Disabilities Act
Americans with Disabilities Act of 1990
The Americans with Disabilities Act of 1990 is a law that was enacted by the U.S. Congress in 1990. It was signed into law on July 26, 1990, by President George H. W. Bush, and later amended with changes effective January 1, 2009....
(ADA). Under Title II, no one can be denied access to public services due to his or her disability
Disability
A disability may be physical, cognitive, mental, sensory, emotional, developmental or some combination of these.Many people would rather be referred to as a person with a disability instead of handicapped...
; it allows those whose rights have been violated to sue
Lawsuit
A lawsuit or "suit in law" is a civil action brought in a court of law in which a plaintiff, a party who claims to have incurred loss as a result of a defendant's actions, demands a legal or equitable remedy. The defendant is required to respond to the plaintiff's complaint...
states for money damages
Damages
In law, damages is an award, typically of money, to be paid to a person as compensation for loss or injury; grammatically, it is a singular noun, not plural.- Compensatory damages :...
.
Tennessee argued that the Eleventh Amendment
Eleventh Amendment to the United States Constitution
The Eleventh Amendment to the United States Constitution, which was passed by the Congress on March 4, 1794, and was ratified on February 7, 1795, deals with each state's sovereign immunity. This amendment was adopted in order to overrule the U.S. Supreme Court's decision in Chisholm v...
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
Board of Trustees of the University of Alabama v. Garrett
Board of Trustees of the University of Alabama v. Garrett, 531 U.S. 356 , was a United States Supreme Court case about Congress's enforcement powers under the Fourteenth Amendment to the Constitution...
(2001), in which the Supreme Court held that Congress had, in enacting certain provisions of the ADA, unconstitutionally abrogated the sovereign immunity
Sovereign immunity
Sovereign immunity, or crown immunity, is a legal doctrine by which the sovereign or state cannot commit a legal wrong and is immune from civil suit or criminal prosecution....
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
City of Boerne v. Flores, 521 U.S. 507 , was a Supreme Court case concerning the scope of Congress's enforcement power under the fifth section of the Fourteenth Amendment...
: 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
Discrimination is the prejudicial treatment of an individual based on their membership in a certain group or category. It involves the actual behaviors towards groups such as excluding or restricting members of one group from opportunities that are available to another group. The term began to be...
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
John Paul Stevens
John Paul Stevens served as an Associate Justice of the Supreme Court of the United States from December 19, 1975 until his retirement on June 29, 2010. At the time of his retirement, he was the oldest member of the Court and the third-longest serving justice in the Court's history...
, the majority ruled that Congress did have enough evidence that the disabled
Americans with disabilities
Americans with disabilities comprise one of the largest minority groups in the United States. According to the Disability Status: 2000 - Census 2000 Brief approximately 20% of Americans have one or more diagnosed psychological or physical disability:...
were being denied those fundamental rights that are protected by the Due Process
Due process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
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 Rehnquist
William Hubbs Rehnquist was an American lawyer, jurist, and political figure who served as an Associate Justice on the Supreme Court of the United States and later as the 16th Chief Justice of the United States...
, and Associate Justices Clarence Thomas
Clarence Thomas
Clarence Thomas is an Associate Justice of the Supreme Court of the United States. Succeeding Thurgood Marshall, Thomas is the second African American to serve on the Court....
, and Antonin Scalia
Antonin Scalia
Antonin Gregory Scalia is an American jurist who serves as an Associate Justice of the Supreme Court of the United States. As the longest-serving justice on the Court, Scalia is the Senior Associate Justice...
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 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.