Supreme Court Denies Cert. in Univ. of Puerto Rico v. Toledo

In Monday's orders list, the Supreme Court denied cert. in University of Puerto Rico v. Toledo. The University of Puerto Rico sought cert. to review a decision of the First Circuit, which held that Title II of the ADA validly abrogates state sovereign immunity in the context of public education. Four circuits have so held; none has come out the other way since the Supreme Court's decision in Tennessee v. Lane.