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Supreme Court of the United States
November 30, 2021, Argued; April 28, 2022, Decided
Chief Justice Roberts delivered the opinion of the Court.
] Congress has broad power under the Spending Clause of the Constitution to set the terms on which it disburses federal funds. “[L]egislation enacted pursuant to the spending power is much in the nature of a contract: in return for federal funds, the [recipients] agree to comply with federally imposed conditions.” Pennhurst State School and Hospital v. Halderman, 451 U. S. 1, 17, 101 S. Ct. 1531, 67 L. Ed. 2d 694 (1981). Exercising this authority, Congress has passed a number of statutes prohibiting recipients of federal financial assistance from discriminating based on certain protected characteristics. We have held that these statutes may be enforced through implied rights of action, and that private plaintiffs may secure injunctive or monetary relief in such suits. See Barnes v. Gorman, 536 U. S. 181, 185, 187, 122 S. Ct. 2097, 153 L. Ed. 2d 230 (2002). Punitive damages, on the other hand, are not available. Id., at 189, 122 S. Ct. 2097, 153 L. Ed. 2d 230. The question presented in this case is whether another special form of damages—damages for emotional distress—may be recovered.
Petitioner Jane Cummings is deaf and legally blind, and communicates primarily in American [*9] Sign Language (ASL). In October 2016, she sought physical therapy services from respondent Premier Rehab Keller, a small business in the Dallas-Fort Worth area. Cummings requested that Premier Rehab provide an ASL interpreter at her appointments. Premier Rehab declined to do so, telling Cummings that she could communicate with the therapist using written notes, lip reading, or gesturing. Cummings then sought and obtained care from another provider.
Cummings later filed this lawsuit against Premier Rehab, alleging that its failure to provide an ASL interpreter constituted discrimination on the basis of disability in violation of the Rehabilitation Act of 1973, §504, 87 Stat. 394, as amended, 29 U. S. C. §794(a), and the Patient Protection and Affordable Care Act, §1557, 124 Stat. 260, 42 U. S. C. §18116. Premier Rehab is subject to these statutes, which apply to entities that receive federal financial assistance, because it receives reimbursement through Medicare and Medicaid for the provision of some of its services. In her complaint, Cummings sought declaratory relief, an injunction, and damages.
Full case includes Shepard's, Headnotes, Legal Analytics from Lex Machina, and more.
2022 U.S. LEXIS 2230 *; __ S.Ct. __; 2022 WL 1243658
JANE CUMMINGS, PETITIONER v. PREMIER REHAB KELLER, P.L.L.C.
Notice: The pagination of this document is subject to change pending release of the final published version.
Prior History: [*1] ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT
Cummings v. Premier Rehab Keller, P.L.L.C., 948 F.3d 673, 2020 U.S. App. LEXIS 2250, 2020 WL 400189 (5th Cir. Tex., Jan. 24, 2020)
Disposition: 948 F. 3d 673, affirmed.
recipients, damages, punitive damages, contracts, remedies, funding, emotional distress damages, cases, analogy, compensatory damages, contract law, notice, emotional suffering, breach of contract, recoverable, emotional distress, contract-law, pecuniary, federal funding, general rule, emotional, serious emotional disturbance, suit for breach, contract action, federal funds, suffering, cause of action, antidiscrimination, discriminating, nonpecuniary
Civil Procedure, Remedies, Injunctions, Constitutional Law, Congressional Duties & Powers, Spending & Taxation, Governments, Legislation, Statutory Remedies & Rights, Damages, Punitive Damages, Monetary Damages, Business & Corporate Compliance, Protection of Rights, Federally Assisted Programs, Enforcement Actions, Education Law, Racial Discrimination, Title VI, Coverage of Title VI, Enforcement of Title VI, Protected Individuals, Discrimination in Schools, Gender & Sex Discrimination, Private Educational Institutions, Contracts Law, Breach, Breach of Contract Actions, Federal Government, Claims By & Against, Torts, Types of Losses, Pain & Suffering, Emotional Distress, Contracts Law, Types of Damages, Compensatory Damages, Courts, Authority to Adjudicate