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Cummingsv.Premier Rehab Keller

CourtSupreme Court of the United States
Docket No.20-219
DecidedApril 28, 2022
Reporter596 U.S. 212
JudgesSupreme Court of the United States
Tags
CivilCivil RightsConstitutional LawStatutory InterpretationDamagesDissent
Case Summary

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.

Opinion

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Cummings V. Premier Rehab Keller — The Atlanta Gleaner