Tennessee v. Lane
United States Supreme Court
541 U.S. 509 (2004)
George Lane (plaintiff) and Beverly Jones sued Tennessee (defendant), alleging the state denied them access to state courthouses because of their disabilities, in violation of Title II of the Americans with Disabilities Act. Tennessee moved to dismiss based on Eleventh Amendment sovereign immunity; the district court denied the motion, and while the appeal was pending, the court of appeals applied the Supreme Court's intervening decision in Board of Trustees of Alabama v. Garrett to hold that ADA suits based on due process (though not equal protection) claims against states could proceed, and found Lane's claims fit that category, affirming the denial of Tennessee's motion.
Whether Title II of the Americans with Disabilities Act, as applied to the right to access the judicial system, validly abrogates state sovereign immunity as an exercise of Congress's Section 5 power to enforce the Fourteenth Amendment.