Cummingsv.Premier Rehab Keller
Jane Cummings, who is deaf and legally blind, requested an American Sign Language interpreter for physical-therapy sessions. Premier Rehab Keller declined and offered other methods of communication. Cummings sued under federal disability-discrimination statutes that apply to entities accepting federal financial assistance and sought emotional-distress damages. The Supreme Court held that those statutes do not authorize emotional-distress damages. Because the statutes operate through Congress’s spending power, recipients must have clear notice of the obligations and remedies attached to the federal funds. The Court concluded that emotional-distress damages were not an available remedy under the relevant contractual-remedies framework and affirmed the judgment for Premier Rehab. Justice Breyer dissented, joined by Justices Sotomayor and Kagan, reasoning that the statutes’ text and remedial purposes supported allowing emotional-distress damages.
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