Cummings v. Premier Rehab Keller

Summary

The Supreme Court held that emotional distress damages are not recoverable in private actions under Spending Clause antidiscrimination statutes, including the Rehabilitation Act and the Affordable Care Act. Applying a contract-law analogy, the Court reasoned that such damages are generally unavailable for breach of contract and that funding recipients lack clear notice of exposure to emotional distress liability. The decision reaffirms the principle from *Barnes v. Gorman* that only remedies traditionally available in contract actions may be implied, and rejects the argument that an exception for contracts likely to cause emotional disturbance applies to discrimination claims.

Questions Presented

1. Whether emotional distress damages are recoverable in a private action to enforce the Rehabilitation Act of 1973 and the Affordable Care Act.