Understanding Tennessee v. Lane and Its Impact on the Disability Community

Demonstrators at the United States Supreme Court, accompanying the story Court To Rule on Protections for Disabled, Associated Press(Jan. 14, 2004). Photographer: Gerald Herbert. Copyright: AP Photos/Gerald Herbert. Reproduced with the permission of the Associated Press.

In the realm of disability rights, few cases have had as profound an impact as Tennessee v. Lane. Decided by the Supreme Court in 2004, this landmark case not only reaffirmed but also strengthened the rights of disabled individuals under the Americans with Disabilities Act (ADA) of 1990. This blog post will explore the background of Tennessee v. Lane, the Supreme Court's decision, and the enduring effects of this case on the disability community.

Background of the Case

Tennessee v. Lane arose from the experiences of George Lane and Beverly Jones, two disabled residents of Tennessee who encountered significant barriers due to their disabilities. George Lane, partially paralyzed from a car accident, was required to appear in a Tennessee court located on the second floor of a building without an elevator. To access the courtroom, Lane had no choice but to crawl up two flights of stairs on his hands and knees, a situation that not only stripped him of his dignity but also highlighted a blatant disregard for accessibility.

Beverly Jones, a certified court reporter whose mobility is also impaired, regularly encountered difficulties related to inaccessible courtrooms. The lack of accommodations not only impeded her ability to perform her job but also restricted her access to public services.

Lane and Jones sued the state of Tennessee under Title II of the ADA, which prohibits discrimination against disabled individuals in all services, programs, and activities provided by state and local government entities. Tennessee argued that Title II of the ADA was an overreach by Congress into the domain of states’ rights, invoking the Eleventh Amendment which grants states sovereign immunity against being sued for damages in federal court by their own citizens.

The Supreme Court's Decision

The case eventually reached the U.S. Supreme Court, which had to consider whether Congress had the authority under the Fourteenth Amendment to abrogate the states' Eleventh Amendment immunity when it enacted Title II of the ADA. The Court’s decision, delivered by Justice John Paul Stevens, affirmed that in instances where states have discriminated against disabled individuals, Congress did indeed have the authority to allow private citizens to sue states for damages under the ADA.

The Court held that Tennessee's refusal to accommodate disabled individuals in state courthouses constituted a "pattern" of unequal treatment in violation of the Fourteenth Amendment's Equal Protection Clause. This decision was pivotal in confirming that individuals with disabilities must have full access to publicly funded services, including courts.

In Lane, the Supreme Court split 5–4. In the majority opinion written by Justice John Paul Stevens, the Court ruled that Congress did have enough evidence that disabled people were being denied those fundamental rights that are protected by the Due Process clause of the Fourteenth Amendment, among those rights being the right to access a court.

Justice Stevens noted in the opinion:

“We confront the question whether Congress had the power under §5 of the Fourteenth Amendment to enforce the constitutional right to access to the courts. We conclude that it did."

Impact on the Disability Community

The ruling was a significant victory for the disability community. It underscored the constitutional backing of the ADA, reaffirming the rights of disabled individuals to participate fully and equally in public life. This case made clear that accessibility is not a privilege but a fundamental right.

Post-Tennessee v. Lane, public entities, especially within the judicial system, have been more vigilant in ensuring that their facilities and services are accessible to all, including disabled individuals. This has led to improvements not just in physical accessibility but also in the availability of auxiliary aids and services that enhance communicative accessibility. I would argue, however, the spirit of the court decision was more significant than the actual application of the law. As I write about in this blog post, I found my jury service experience to be less than accommodating and inclusive.

The case brought national attention to the challenges faced by disabled individuals, driving greater awareness and advocacy efforts focused on eliminating barriers and expanding rights and accommodations for the disability community. The decision set a legal precedent that has been used in numerous subsequent cases involving discrimination against disabled persons. It serves as a crucial reference point for courts dealing with issues of accessibility and discrimination under the ADA.

Tennessee v. Lane has encouraged states to proactively examine and modify their policies, practices, and physical infrastructures to avoid violating the ADA. This proactive compliance helps to prevent discrimination before it occurs, rather than merely addressing it after the fact.

I would be remiss if I didn’t mention that Chief Justice William Rehnquist and Associate Justices Clarence Thomas and Antonin Scalia all filed dissents. Justice Thomas is still on the bench and continues to vote against the Constitutional protections of the ADA. It is paramount that disability advocates remain vigilant against future SCOTUS erosion of laws protecting the civil rights of disabled people.