article: 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: On August 10, 1998, two paraplegic wheelchair users filed a class action suit in federal court against the State of Tennessee and several of its counties. The Plaintiffs alleged that the defendants had unlawfully discriminated against them by failing to make county courthouses physically accessible to individuals with mobility impairments, in violation of Title II of the Americans with Disabilities Act. Tennessee motioned to have the case dismissed, arguing the Title II of the ADA violated the Eleventh Amendment of the Constitution. The court denied this motion, and Tennessee appealed. The appeal eventually reached the Supreme Court, which on May 17, 2004, upheld the lower court's decision to deny the motion to dismiss. Shortly after the Supreme Court decision, the District Court denied the plaintiffs motion to certify the class. The case proceeded with the named plaintiffs only. In February and March of 2005, the Plaintiffs entered separate settlements with Tennessee and each of the defendant counties, wherein the defendants agreed to physically modify the courthouses and to appoint a total of 95 Judicial Program ADA Coordinators to ensure ADA compliance. The defendants also agreed to pay the Plaintiffs a total of $972,000 in legal fees.