LANE v. PENA, SECRETARY OF TRANSPORTATION, ET AL.
518 U.S. 187 (1996)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A waiver of the Federal Government's sovereign immunity against monetary damages must be unequivocally expressed in the statutory text and will be strictly construed in favor of the sovereign; it cannot be implied from the statute's purpose or legislative history.
Facts:
- James Griffin Lane enrolled as a student at the United States Merchant Marine Academy, a federal service academy administered by the Department of Transportation.
- During his first year at the Academy, Lane was diagnosed with diabetes mellitus.
- Lane disclosed his diabetes diagnosis to the Academy's medical staff.
- In December 1992, the Academy separated Lane on the grounds that his diabetes was a 'disqualifying condition' for a commission in the Navy/Merchant Marine Reserve Program.
Procedural Posture:
- James Lane sued the Secretary of the Department of Transportation in the U.S. District Court for the District of Columbia, seeking reinstatement and compensatory damages.
- The District Court granted summary judgment for Lane, ordered his reinstatement, and initially ruled he was entitled to compensatory damages.
- Following an intervening decision by the appellate court in an unrelated case (Dorsey), the District Court vacated its order awarding monetary damages to Lane.
- Lane appealed the denial of damages to the U.S. Court of Appeals for the District of Columbia Circuit.
- The Court of Appeals summarily affirmed the District Court's decision, denying the damages award based on its precedent in Dorsey.
- The U.S. Supreme Court granted certiorari to resolve a split among the circuit courts on this issue.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does Section 504(a) of the Rehabilitation Act of 1973 contain an unequivocal waiver of the Federal Government's sovereign immunity, thereby permitting an award of monetary damages against a federal Executive agency for disability discrimination?
Opinions:
Majority - Justice O’Connor
No. The Rehabilitation Act of 1973 does not contain an unequivocal waiver of the Federal Government's sovereign immunity against monetary damages for violations of § 504(a) by Executive agencies. The Court's precedents require that a waiver of sovereign immunity be unequivocally expressed in the statutory text and strictly construed in favor of the sovereign. The Act's remedies provision, § 505(a)(2), makes the remedies of Title VI (which include monetary damages) available against a 'recipient of Federal assistance or Federal provider of such assistance,' but it conspicuously omits the broader language from § 504(a) covering 'any program or activity conducted by any Executive agency.' This omission creates an ambiguity that must be resolved in favor of immunity. The statutory scheme, while 'bewildering,' does not provide the necessary clear statement, especially when contrasted with other sections of the Act where Congress did craft clear waivers for other types of claims.
Dissenting - Justice Stevens
Yes. The majority incorrectly concludes there is no waiver by ignoring the Act's clear intent, text, and legislative history. Section 504 was modeled after Title VI of the Civil Rights Act, which was understood to authorize a damages remedy. When Congress amended § 504 in 1978 to cover Executive agencies, it intended to apply the same remedial scheme, including damages, to all violators. The majority misreads § 505(a)(2) as a limitation on remedies; it was meant to codify existing enforcement practices for federal grant recipients, not to create a special immunity for Executive agencies discriminating in their own programs. The majority's holding creates an illogical result where the government is liable for damages when it funds discrimination but not when it discriminates directly.
Analysis:
This decision solidifies the 'clear statement rule' for waiving federal sovereign immunity, requiring Congress to be exceptionally explicit in the statutory text to permit monetary damages against the government. It significantly curtails the ability of litigants to infer a damages remedy against a federal agency from a statute's general structure or purpose. The ruling creates a bifurcated system of remedies under the Rehabilitation Act, where victims of discrimination by state or private recipients of federal funds can recover damages, while victims of identical discrimination by a federal agency acting in a non-funding capacity cannot. This has a substantial impact on civil rights litigation, placing a heavy burden on legislative drafters to use specific 'magic words' to waive immunity.
Unlock the full brief for LANE v. PENA, SECRETARY OF TRANSPORTATION, ET AL.