Tennessee v. Lane (2004)

By: Eowyn Dautrich

Overview:

Tennessee v. Lane (2004) is a Supreme Court case in which plaintiffs George Lane and Beverly Jones filed suit against the State of Tennessee and the appropriate counties, alleging there had been an ongoing violation of Title II of the Americans with Disabilities Act (ADA). The plaintiffs, both being paraplegics who use wheelchairs for mobility, claimed they were denied access to, and the services of, court systems due to their disabilities. The defendants moved to dismiss the suit on the basis of the protection of the Eleventh Amendment. The primary issue in this case is if Congress can validly exercise the enforcement power under §5 of the Fourteenth Amendment, thereby abrogating the states’ sovereign immunity and allowing citizens to sue states for violations of Title II of the ADA. 

Summary: 

In August 1998, paraplegic plaintiffs, George Lane and Beverly Jones, alleged that they were denied access to, and the services of, the state court system by reason of their disabilities, violating Title II of the ADA. Lane alleged that he was ordered to answer a set of criminal charges on the second floor of a county courthouse that had no elevator. At Lane’s first court appearance, he had to crawl up two flights of stairs to get to the courtroom. During his second appearance, Lane refused to crawl again or be carried by officers to the courtroom and was consequently arrested and jailed for failure to appear before the court. Jones, a court reporter, alleged that she had not been given access to numerous county courthouses and, as a result, had lost work and opportunities to participate in judicial processes. Both Lane and Jones sought damages and equitable relief [1]. 

In response, the State of Tennessee moved to dismiss the suit on the grounds of the Eleventh Amendment, rendering states immune from “any suit in law or equity, commenced or prosecuted ... by Citizens.” Although the Amendment states only citizens of another State or Foreign Country, it has repeatedly been applied to unconsented suits brought by a State’s own citizens (Tennessee v. Lane). The District Court denied the motion, and the State appealed.

On April 28, 2000, the Court of Appeals for the Sixth Circuit entered an order suspending the case pending the Supreme Court’s decision in Board of Trustees of Univ. of Ala. v. Garrett (Tennessee v. Lane). In Garrett, the Supreme Court concluded that Title I of the ADA does not allow private suits seeking damages against states for violations after applying the “congruence and proportionality” test derived from City of Boerne v. Flores. Therefore, Title I of the ADA does not have the power to nullify the states’ sovereign immunity. However, Garrett left courts questioning if Congress could enact §5 of the Fourteenth Amendment to abrogate state sovereign immunity under Title II of the ADA [1].

When the ADA was passed, Congress found that individuals with disabilities had faced discrimination, unequal treatment, and political powerlessness, which led to the establishment of the three Titles of the ADA (Tennessee v. Lane). Title II prohibits public entities from discriminating against individuals with disabilities and defines public entities to include local governments and their agencies and instrumentalities. Additionally, Title II incorporates § 505 of the Rehabilitation Act, which authorizes private individuals to bring suits for damages. However, the Eleventh Amendment raises the question of whether plaintiffs can hold states accountable for damages [3]. Consequently, the Supreme Court granted certiorari to determine whether Title II validly abrogates state sovereignty when constitutional violations are identified.

On January 13, 2004, the case was argued before the Supreme Court. The plaintiffs established a pattern of unconstitutional treatment through previous decisions by other courts, each documenting unequal treatment in public services, programs, activities, penal systems, public education, and voting. Additionally, these decisions highlighted a pattern of unconstitutional treatment in the administration of justice. This pattern of discrimination against persons with disabilities persisted despite several federal and state legislative reforms intended to address it [1].

Further evidence, in the form of hundreds of examples of unequal treatment of persons with disabilities by states and their political subdivisions, was also uncovered via private investigation and testaments. Specifically, Congress learned that individuals in many states across the country were being excluded from courthouses and court proceedings because of their disabilities, with 76% of courthouses being inaccessible and unusable by persons with disabilities [1].

As a result, the Supreme Court was split 5-4 and concluded that Title II, as applied to the fundamental right of access to the courts, was a valid exercise of Congress’s § 5 authority under the Fourteenth Amendment. Congress therefore required states to take reasonable measures to remove barriers to accessibility, including “reasonable modifications” that do not alter the nature of the service provided (Tennessee v. Lane). 

In March 2005, the plaintiffs reached settlements with the defendants. Tennessee agreed to pay $905,000 in attorneys’ fees and costs and ensure ADA compliance in state and county courthouses. The counties agreed to make the courts accessible to individuals with mobility impairments, appoint ADA coordinators, and pay $67,000 in attorneys’ fees and costs. The plaintiffs did not individually receive any damages [2]. 

Impact:

The Supreme Court held that states’ sovereign immunity can be overruled by Congress under § 5 of the Fourteenth Amendment, holding states and local governments accountable if Title II of the ADA were to be violated and granting citizens the right to file suit for damages. Nationally, this led to improvements in the accessibility of courts and other public entities, including increased physical access and the availability of auxiliary aids for persons with disabilities. In conclusion, the Supreme Court set a legal precedent that accessibility is a fundamental right protected by the Constitution, upholding the application of the Americans with Disabilities Act under Title II [4]. 

Court Documents

Tennessee v. Lane, 541 U.S. 509 (2004) (124 S. Ct. 1978; 158 L. Ed. 2d 820).

Citations: 

[1] Tennessee v. Lane, Justia U.S. Supreme Court Center, https://supreme.justia.com/cases/federal/us/541/509/#top. Accessed 11 September, 2026.

[2] Lane v. Tennessee, Civil Rights Litigation Clearinghouse, University of Michigan Law School, https://clearinghouse.net/case/5518/. Accessed 11 September, 2026.

[3] Tennessee v. Lane: The Legal Issues and the Implications for People with Disabilities, National Council on Disability, https://www.ncd.gov/report/tennessee-v-lane-the-legal-issues-and-the-implications-for-people-with-disabilities/. Accessed 13 September, 2026.

[4] Yarborough, Jody. “Understanding Tennessee v. Lane and Its Impact on the Disability Community.” Love Disabled Life, https://www.lovedisabledlife.com/blog/understanding-tennessee-v-lane-and-its-impact-on-the-disability-community. Accessed 15 September, 2026.