Tennessee v. Lane
United States Supreme Court
541 U.S. 549 (2004)
George Lane (plaintiff) and Beverly Jones filed suit in federal district court against the state of Tennessee (defendant) alleging that the state violated Title II of the Americans with Disabilities Act of 1990 by denying them access to state courthouses due to their disabilities. The state moved to dismiss the complaint on the ground of Eleventh Amendment state immunity from non-consensual suit. The district court denied the state’s motion and the state appealed. The court of appeals stayed review of the case pending the United States Supreme Court’s decision in Board of Trustees of Alabama v. Garrett, 532 U.S. 356 (2001). The court of appeals interpreted Garrett to prohibit private suits based on equal protection claims against states under the Americans with Disabilities Act, but to allow suits against states based on due process violations. The court of appeals concluded that Lane’s claims were based on due process violations and affirmed the district court’s decision to deny the state’s motion for dismissal. The state petitioned the United States Supreme Court for review.
Rule of Law
Holding and Reasoning (Stevens, J.)
Concurrence (Souter, J.)
Concurrence (Ginsburg, J.)
Dissent (Rehnquist, C.J.)
Dissent (Scalia, J.)
Dissent (Thomas, J.)
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