Cummings v. Premier Rehab Keller

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Remedies
  • Date Filed: April 28, 2022
  • Case #: 20-219
  • Judge(s)/Court Below: ROBERTS, C. J., delivered the opinion of the Court, in which THOMAS, ALITO, GORSUCH, KAVANAUGH, and BARRETT, JJ., joined. KAVANAUGH, J., filed a concurring opinion, in which GORSUCH, J., joined. BREYER, J., filed a dissenting opinion, in which SOTOMAYOR and KAGAN, JJ., joined.
  • Full Text Opinion

Emotional distress damages are not recoverable in private actions of Spending Clause antidiscrimination statutes.

Petitioner filed an action seeking emotional distress damages against Respondent after Respondent declined to provide an ASL interpreter for the Petitioner as she was legally blind and deaf. Petitioner argued Respondent’s action constitutes grounds of discrimination based on disability that violated the Rehabilitation Act of 1973 and the Affordable Care Act, in which Respondent is subject to because they receive federal funds. The District Court dismissed the claim because emotional distress damages are not recoverable in private actions enforceable under these statutes. The Court of Appeals affirmed. The Court reasoned that acceptance of funds under these statutes is likened to a contract with the federal government. Respondent is subject to the explicit and traditional breach of contract remedies available, and Respondent must have notice of potential liability when accepting the federal funding. The Court found emotional distress damages are not traditional remedies in suits for breach of contract and Respondent was not on notice that they would face that remedy in private actions brought to enforce these statutes. Therefore, The Court held private actions seeking to enforce Spending Clause antidiscrimination statutes cannot recover emotional distress damages. AFFIRMED.

Advanced Search


Back to Top