Tennessee v. Lane, 541 U.S. 509 (2004), was a case in the Supreme Court of the United States involving Congress's enforcement powers under section 5 of the Fourteenth Amendment.
Under Title II, no one can be denied access to public services due to his or her disability; it allows those whose rights have been violated to sue states for money damages.
It relied principally on Board of Trustees of the University of Alabama v. Garrett (2001), in which the Supreme Court held that Congress had, in enacting certain provisions of the ADA, unconstitutionally abrogated the sovereign immunity of the States by letting people sue the States for discrimination on the basis of disability.
Garrett had held that Congress had not met the congruent-and-proportional test – i.e., that it had not amassed enough evidence of discrimination on the basis of disability to justify the abrogation of sovereign immunity.
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.