Tennessee v. Lane

No. 3:98 CV 0731 (M.D. Tenn. March 23, 2005) ; Clearinghouse Number: 55480

Description

Supreme Court Finds that ADA’s Title II Is a Valid Exercise of Congress’ Section 5 Enforcement Powers

Abstract

The U.S. Supreme Court held that, as applied to the class of cases implicating the fundamental right of access to the courts, Title II of the Americans with Disabilities Act (ADA) constituted a valid exercise of Congress’ authority under Section 5 of the Fourteenth Amendment. Plaintiffs alleged that courthouses in twenty-three Tennessee counties are not physically accessible to individuals with mobility impairments. One plaintiff was arrested for failure to appear when he refused to crawl up the steps of an inaccessible courthouse to attend a hearing in his criminal case. Plaintiffs claimed that defendant’s failure to make state courthouses accessible violated ADA’s Title II. The district court denied defendants’ motion to dismiss on Eleventh Amendment grounds. The Sixth Circuit affirmed, finding that Title II validly abrogated state sovereign immunity in cases in which the statute enforced due process principles. Affirming, the Supreme Court held that Title II was a valid exercise of Congress’ Section 5 enforcement power. The Court noted that Congress enacted Title II against a backdrop of pervasive unequal treatment of persons with disabilities in the administration of state services and programs, including systematic deprivation of fundamental rights. The Court found that the extensive record of disability discrimination underlying Congress’ findings in the ADA made clear that inadequate provision of public services and access to public facilities was an appropriate subject for prophylactic legislation. The Court also held that Title II was an appropriate response to the history and pattern of unequal treatment of persons with disabilities and was valid Section 5 legislation as it applied to the class of cases implicating the accessibility of judicial services. However, Title II does not require states, the Court noted, to employ any and all means to make judicial services accessible or to compromise essential eligibility criteria for public programs. It requires only “reasonable modification” that would not fundamentally alter the nature of the service provided, and only when the individual seeking modification is otherwise eligible for the service.

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Docket Date
2005-03-23 00:00:00+00:00

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