Tennessee v. Lane

Congress passed Title II of the Disabilities Act of 1990, which provides that “no qualified individual with a disability shall, by reason of such disability, be excluded from participation in or be denied the benefits of the services, programs or activities of a public entity, or be subjected to discrimination by any such entity.”

Whether Title II of the Disabilities Act exceeds Congress’s power under section 5 of the 14th Amendment.

Title II’s requirement of program accessibility is congruent and proportional to its object of enforcing the right of access to the courts, and is a reasonable prophylactic measure, reasonably targeted to a legitimate end.

To determine whether Congress may abrogate a State’s Eleventh Amendment immunity, the court must consider 1) whether Congress unequivocally expressed its intent to abrogate that immunity; and 2) if it did, whether Congress acted pursuant to a valid grant of constitutional authority.