Filed Date: Aug. 10, 1998
Closed Date: 2005
Clearinghouse coding complete
On August 10, 1998, two named plaintiffs, both of whom had paraplegia and used wheelchairs, filed a class action lawsuit in the United States District Court for the Middle District of Tennessee, against the State of Tennessee and 25 Tennessee counties. The plaintiffs alleged past and ongoing violations of Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. §§12131-12165. The plaintiffs claimed that they had been denied access to the Tennessee state court system because of their disabilities. One plaintiff alleged that when he was ordered to appear at a county courthouse whose courtroom was on the second floor without elevator access, he had to crawl up two flights of stairs to reach the courtroom. When he next returned to the courthouse he refused to pull himself up the stairs again and for safety reasons declined being carried up by security personnel. As a result he was arrested and jailed for failure to appear. The other plaintiff was a certified court reporter who alleged that because she was not able to access many Tennessee county courthouses she lost work opportunities and was denied the opportunity to participate in the judicial process. The plaintiffs sought money damages and injunctive relief to modify the inaccessible courthouses.
On October 5, 1998, Tennessee moved to have the case dismissed on Eleventh Amendment Grounds, arguing that Title II of the ADA was invalid to the extent that it authorized private parties to file federal lawsuits for money damages against states. On November 10, 1998, the District Court denied this motion. Tennessee appealed to the federal Sixth Circuit Court of Appeals, and proceedings in the district court were stayed while this appeal was pending. On July 16, 2002, the Sixth Circuit Court of Appeals affirmed the District Court's denial of the motion to dismiss (Judge Boyce F. Martin, Jr writing for a three-judge panel). Lane v. Tennessee, 40 Fed.Appx. 911 (2012). The Court of Appeals granted a rehearing on the issue before the same three-judge panel, and on January 10, 2003 it issued an Amended Judgment, wherein the Court (Judge Martin) again affirmed the lower court's decision and explained that, because the Plaintiffs were "seeking to vindicate" their due process "right of access to the courts," the action was not barred by the Eleventh Amendment. Lane v. Tennessee, 315 F.3d 680 (2003).
Tennessee petitioned for certiorari from the Supreme Court of the United States, and the Supreme Court granted certiorari. At this point the United States of America, represented by attorneys from Department of Justice Civil Rights Division, joined the Plaintiffs as respondents. On May 17, 2004, the Supreme Court, in an opinion by Justice John Paul Stevens, upheld the constitutionality of the ADA's application against states. The Court found that Congress had abundant evidence that the states frequently denied people with disabilities fundamental rights protected by the Due Process clause of the Fourteenth Amendment, including the right to access courts. Further, the remedy Congress enacted was congruent and proportional, because the "reasonable accommodations" mandated by the ADA were not unduly burdensome and disproportionate to the harm. Garrett, the Court said, covered only Equal Protection claims, not Due Process claims. Therefore the law was constitutional. Tennessee v. Lane, 541 U.S. 509 (2004).
On August 17, 2004, the District Court denied the Plaintiffs' motion to certify the class, finding that the question of whether each particular member of the proposed class was discriminated against because of their disability would need to be determined on an individual basis, considering the conditions of the particular courthouses, and that therefore class action was inappropriate. Shortly thereafter the parties began negotiating settlements.
In February and March of 2005, the Plaintiffs entered separate settlements with the State of Tennessee and with each of the defendant counties. Tennessee agreed to pay the Plaintiffs $905,000 in attorneys' fees and costs. Tennessee also agreed to recommend to the Tennessee Supreme Court that it implement a comprehensive policy ensuring ADA compliance at state and county courthouses.
Each of the counties agreed to make modifications to their courthouses to make them accessible to wheelchair users and other people with mobility impairments. The Defendants agreed to cooperate in the appointment of ninety-five Local Judicial Program ADA Coordinators. Each county agreed to pay $2,680, totaling $67,000, in attorneys' fees and costs. The Plaintiffs did not receive money damages.
Summary Authors
Alex Colbert-Taylor (6/12/2013)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/6140689/parties/lane-v-tennessee-state-of/
Breyer, Stephen Gerald (District of Columbia)
Campbell, Todd J. (Tennessee)
Ginsburg, Ruth Bader (District of Columbia)
Griffin, Juliet E. (Tennessee)
Higgins, Thomas Aquinas (Tennessee)
Martin, Boyce Ficklen Jr. (Kentucky)
O'Connor, Sandra Day (District of Columbia)
Rehnquist, William Hubbs (District of Columbia)
Scalia, Antonin (District of Columbia)
Siler, Eugene Edward Jr. (Kentucky)
Breyer, Stephen Gerald (District of Columbia)
Campbell, Todd J. (Tennessee)
Ginsburg, Ruth Bader (District of Columbia)
Griffin, Juliet E. (Tennessee)
Higgins, Thomas Aquinas (Tennessee)
Martin, Boyce Ficklen Jr. (Kentucky)
O'Connor, Sandra Day (District of Columbia)
Rehnquist, William Hubbs (District of Columbia)
Scalia, Antonin (District of Columbia)
Siler, Eugene Edward Jr. (Kentucky)
Souter, David Hackett (District of Columbia)
Stevens, John Paul (District of Columbia)
Suhrheinrich, Richard Fred (Michigan)
Thomas, Clarence (District of Columbia)
Bagenstos, Samuel R. (Massachusetts)
Brown, William J. (Tennessee)
Burnim, Ira Abraham (District of Columbia)
Dardarian, Linda M. (California)
Goldstein, Thomas C. (District of Columbia)
Housepian, Gary D. (Tennessee)
Lafferty, Martha M. (Tennessee)
Steele, Roberta L. (California)
Collier, Mary Martelle (Tennessee)
Donnell, Thomas M. Jr. (Tennessee)
Draper, William Lawrence (Tennessee)
Mantooth, David Randall (Tennessee)
McMurtry, Sarannah L. (Tennessee)
Moore, Michael E. (Tennessee)
Ogle, Stephen S. (Tennessee)
Quinn, John E. (Tennessee)
Reeves, Pamela Lynn (Tennessee)
Rhea, Floyd (Tennessee)
Rowell, Nathan D. (Tennessee)
Stanley, Larry B. (Tennessee)
Summers, Paul G. (Tennessee)
Tolson, Peggy (Tennessee)
Upchurch, Howard L. (Tennessee)
Anderson, Kristyn (Minnesota)
Archer, Dennis W. (Illinois)
Armstrong, Timothy K. (District of Columbia)
Arnwine, Barbara R. (District of Columbia)
Asbill, Sutherland (Georgia)
Babcock, Sherril Nell (California)
Booth, David M. (District of Columbia)
Bossing, Lewis (California)
Bowker, David W. (Illinois)
Brady, M. Jane (Delaware)
Broy, Andrew W. (Georgia)
Bruning, Jon (Nebraska)
Carbonez, Kristien (District of Columbia)
Center, Claudia B. (California)
Crank, Patrick J. (Wyoming)
Cunningham, Gary R. (Minnesota)
Dadey, Kristin M. (District of Columbia)
Danzig, Deborah M. (Georgia)
Davies, David W. (Kansas)
DeZago, Ralph James (Kansas)
Dillickrath, Thomas (District of Columbia)
Edmondson, W. A. Drew (Oklahoma)
Eng, Vincent A. (District of Columbia)
Foreman, Michael L. (District of Columbia)
Forrester, Nathan A. (Alabama)
Galanter, Seth Michael (District of Columbia)
Gans, Abbey (New York)
Groseclose, Richard (District of Columbia)
Harrington, Sarah E. (District of Columbia)
Hatch, Mike (Minnesota)
Haun, Kathryn R. (Alabama)
Hayes, Dennis Courtland (Maryland)
Henderson, Thomas J. (District of Columbia)
Ide, Jennifer N. (Georgia)
Kennedy, Harry (Kansas)
Kline, Phill (Kansas)
Kristen, Elizabeth (California)
Lawson, Nicole D. (Georgia)
Lester, Charles Jr. (Georgia)
Lieberman, Michael (New York)
Maer, Foster (New York)
Mathis, Jennifer (District of Columbia)
Mayerson, Arlene Brynne (California)
McAhren, Kristen (District of Columbia)
McCallum, Elizabeth B. (District of Columbia)
Menard, Richard H. Jr. (Alabama)
Minceberg, Elliot (District of Columbia)
Oppenheimer, James Chad (District of Columbia)
Pryor, William Holcombe Jr. (Alabama)
Rich, John Townsend (District of Columbia)
Rockoff, Jennifer M. (Illinois)
Roseborough, Teresa Wynn (Georgia)
Russell, Kevin K. (District of Columbia)
Sandoval, Brian Edward (Nevada)
Schaerr, Gene C. (District of Columbia)
Shurtleff, Mark L. (Utah)
Silver, Jessica Dunsay (District of Columbia)
Sinkfield, Richard H. (Georgia)
Stenehjem, Wayne (North Dakota)
Tower, Andrew P. (District of Columbia)
Wolfson, Paul R. Q. (Illinois)
Yee, Silvia (California)
See docket on RECAP: https://www.courtlistener.com/docket/6140689/lane-v-tennessee-state-of/
Last updated May 14, 2023, 3:01 a.m.
State / Territory: Tennessee
Case Type(s):
Special Collection(s):
Key Dates
Filing Date: Aug. 10, 1998
Closing Date: 2005
Case Ongoing: No
Plaintiffs
Plaintiff Description:
Paraplegics alleging that Tennessee and a number of its counties had denied them physical access to that State’s courts
Plaintiff Type(s):
Attorney Organizations:
NDRN/Protection & Advocacy Organizations
U.S. Dept. of Justice Civil Rights Division
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: Yes
Class Action Outcome: Denied
Defendants
Defendant Type(s):
Case Details
Causes of Action:
Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12111 et seq.
Available Documents:
U.S. Supreme Court merits opinion
Outcome
Prevailing Party: Plaintiff
Nature of Relief:
Injunction / Injunctive-like Settlement
Source of Relief:
Form of Settlement:
Court Approved Settlement or Consent Decree
Amount Defendant Pays: $972,000
Order Duration: 2005 - None
Content of Injunction:
Develop anti-discrimination policy
Goals (e.g., for hiring, admissions)
Issues
General:
Access to public accommodations - governmental
Discrimination-basis:
Disability (inc. reasonable accommodations)
Disability:
Type of Facility: