## Facts

- George Lane, a paraplegic who used a wheelchair, was required to appear in a Tennessee state criminal court located on an upper floor of a courthouse without an elevator.
- Lane crawled up two flights of stairs to attend one court date; on a later date he refused to crawl or be carried, did not appear, and was arrested and charged with failure to appear.
- Beverly Jones, a wheelchair-using court reporter, alleged she could not physically access multiple county courthouses where she sought work.
- Lane, Jones, and others sued Tennessee and several counties under Title II of the Americans with Disabilities Act (ADA), alleging denial of physical access to courts and other judicial services.
- Plaintiffs sought money damages and equitable relief.

## Issues

1. Whether Congress, through Title II of the ADA, validly abrogated state sovereign immunity under § 5 of the Fourteenth Amendment as applied to cases involving access to judicial services.
2. Whether Title II’s remedial scheme, as applied to access-to-courts claims, is congruent and proportional to the constitutional injuries Congress sought to prevent or remedy.

## Decision

- The Supreme Court affirmed the denial of Tennessee’s motion to dismiss on Eleventh Amendment grounds (5–4).
- The Court held that, as applied to the class of cases implicating the fundamental right of access to the courts, Title II is a valid exercise of Congress’s § 5 enforcement power.
- Because Title II validly enforces the Fourteenth Amendment in this context, Congress validly abrogated state sovereign immunity, permitting private suits for money damages against a State for denying meaningful access to courts.

## Legal Principles

- Congress may abrogate state sovereign immunity when it (1) clearly states its intent to do so and (2) acts pursuant to a valid grant of constitutional authority.
- Under § 5 of the Fourteenth Amendment, enforcement legislation must exhibit congruence and proportionality between the injury to be prevented or remedied and the means adopted.
- The Due Process Clause protects a fundamental right of access to the courts, including a meaningful opportunity to be heard.
- In access-to-courts cases, Title II’s requirements (including reasonable modifications, subject to limits for fundamental alteration and undue burdens) are a congruent and proportional response to documented barriers and exclusion in judicial services.

## Conclusion

The Court held that Title II of the ADA validly abrogates state sovereign immunity when applied to claims alleging denial of meaningful access to courts, allowing private damages actions against a State for disability-based barriers to judicial services.


Tennessee v. Lane, 541 U.S. 509 (2004)