United States Supreme Court

Barnes v. Gorman

Certiorari To The United States Court Of Appeals For The Eighth Circuit
No. 01-682.   Decided
June 17, 2002.
Full text:  http://supct.law.cornell.edu/supct/html/01-682.ZS.html 

This is not an employment case.  Gorman, a paraplegic, suffered serious injuries that left him unable to work full time when, after arrest, he was transported to a Kansas City police station in a van that was not equipped to accommodate the disabled. He sued police officials and officers for discriminating against him on the basis of his disability, in violation of 202 of the Americans with Disabilities Act of 1990 (ADA) and 504 of the Rehabilitation Act of 1973, by failing to maintain appropriate policies for the arrest and transportation of persons with spinal cord injuries. A jury awarded him compensatory and punitive damages, but the District Court vacated as to punitive damages, holding that they are unavailable in private suits brought under 202 of the ADA and 504 of the Rehabilitation Act. In reversing, the Eighth Circuit found punitive damages available under the “general rule” of Franklin v. Gwinnett County Public Schools, 503 U.S. 60, that “absent clear direction to the contrary by Congress, the federal courts have the power to award any appropriate relief” for violation of a federal right.

The United States Supreme Court held that punitive damages may not be awarded in private suits brought under 202 of the ADA and 504 of the Rehabilitation Act. These sections are enforceable through private causes of action, whose remedies are coextensive with those available in a private action under Title VI of the Civil Rights Act of 1964. See 203 of the ADA and 505(a)(2) of the Rehabilitation Act. Title VI invokes Congress’s Spending Clause power to place conditions on the grant of federal funds. The Supreme Court has regularly applied a contract-law analogy in defining the scope of conduct for which funding recipients may be held liable in money damages, and in finding a damages remedy available, in private suits under Spending Clause legislation. The same analogy applies in determining the scope of damages remedies. A remedy is appropriate relief only if the recipient is on notice that, by accepting federal funding, it exposes itself to such liability. A funding recipient is generally on notice that it is subject not only to those remedies explicitly provided in the relevant legislation but also to those traditionally available in breach of contract suits. Title VI mentions no remedies; and punitive damages are generally not available for breach of contract. Nor could it be said that Title VI funding recipients have, merely by accepting funds, implicitly consented to a remedy which is not normally available for contract actions, and the indeterminate magnitude of which could produce liability exceeding the level of federal funding. Because punitive damages may not be awarded in private suits under Title VI, it follows that they may not be awarded in suits under 202 of the ADA and 504 of the Rehabilitation Act. 

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