Barnes v. Gorman
153 L. Ed. 2d 230, 2002 U.S. LEXIS 4421, 536 U.S. 181 (2002)
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Rule of Law:
Punitive damages are not an available remedy in private causes of action brought under § 202 of the Americans with Disabilities Act (ADA) and § 504 of the Rehabilitation Act because those statutes' remedies are coextensive with Title VI of the Civil Rights Act, which, as Spending Clause legislation, is interpreted through a contract-law analogy where punitive damages are not a traditional remedy.
Facts:
- Jeffrey Gorman, a paraplegic man who uses a wheelchair and a catheter with a urine bag, was arrested for trespass after a fight at a nightclub in Kansas City, Missouri.
- While awaiting transport, police officers denied Gorman's request to use a restroom to empty his urine bag.
- The police van that arrived was not equipped for a wheelchair.
- Officers removed Gorman from his wheelchair and strapped him to a narrow bench in the van using a seatbelt and his own belt.
- During the transport, Gorman's belt came loose, and he fell to the floor, rupturing his urine bag and injuring his shoulder and back.
- As a result of these events, Gorman suffered serious and lasting medical problems, including a bladder infection, severe back pain, and uncontrollable spasms, which left him unable to work full time.
Procedural Posture:
- Jeffrey Gorman brought suit against the Kansas City Board of Police Commissioners and other police officials in the U.S. District Court for the Western District of Missouri.
- A jury found the petitioners liable and awarded over $1 million in compensatory damages and $1.2 million in punitive damages.
- The District Court granted the petitioners' motion to vacate the punitive damages award, holding they were unavailable under the relevant statutes.
- Gorman, as appellant, appealed the vacatur to the U.S. Court of Appeals for the Eighth Circuit.
- The Eighth Circuit reversed the District Court, reinstating the punitive damages award.
- The police officials, as petitioners, were granted a writ of certiorari by the U.S. Supreme Court.
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Issue:
Are punitive damages an available remedy in private suits brought under § 202 of the Americans with Disabilities Act (ADA) and § 504 of the Rehabilitation Act?
Opinions:
Majority - Justice Scalia
No. Punitive damages may not be awarded in private suits brought under § 202 of the ADA and § 504 of the Rehabilitation Act. The remedies for these statutes are tied to Title VI of the Civil Rights Act, which is Spending Clause legislation. Spending Clause legislation is analyzed like a contract between the government and the funding recipient. A recipient is only liable for remedies it is on notice of when accepting federal funds. Because punitive damages are not a traditional remedy for breach of contract, recipients of federal funds have not implicitly consented to being liable for them.
Concurring - Justice Souter
I agree that the contract-law analogy is appropriate here and leads to the conclusion that punitive damages are unavailable. The indeterminate magnitude of punitive damages means a funding recipient could not have reasonably anticipated such liability. However, this contract analogy may not provide clear answers to all questions under Spending Clause legislation, such as the proper measure of compensatory damages.
Concurring - Justice Stevens
I agree with the judgment but not the reasoning. The case should be decided on the narrower ground that municipalities are immune from punitive damages under the precedent of Newport v. Fact Concerts, Inc. The majority's reliance on a broad contract-law analogy based on Pennhurst is inappropriate because it was not argued below and extends that analogy to statutes like the ADA that are not based on the Spending Clause. This novel reliance on a contract analogy has potentially far-reaching and unforeseen consequences.
Analysis:
This decision solidifies the use of a contract-law analogy to interpret the scope of remedies available under federal Spending Clause legislation. By treating federal funding as a 'contract,' the Court requires that recipients have clear notice of the liabilities they are accepting, effectively ruling out remedies not traditionally available for breach of contract, such as punitive damages. This holding significantly limits the potential financial liability for recipients of federal funds who are sued for discrimination under statutes like the ADA and Rehabilitation Act. The ruling creates a uniform, albeit restrictive, standard for remedies under these acts by tying them to the more limited remedies available under Title VI.
