Barnes v. Gorman

United States Supreme Court · 2002 · Federal Courts

Federal CourtsADARehabilitation ActSpending ClauseRemediespunitive damagesTitle VITitle II ADA

Facts

Jeffrey Gorman, a paraplegic who used a wheelchair and a catheter urine bag, was arrested by Kansas City police. Because the police van could not accommodate his wheelchair, officers strapped him to a narrow bench; during transport he fell, ruptured his urine bag, and injured his shoulder and back. He sued Kansas City police officials, alleging disability discrimination under § 202 of the ADA and § 504 of the Rehabilitation Act based on failure to maintain appropriate arrest and transportation policies for persons with spinal cord injuries. A jury awarded more than $1 million in compensatory damages and $1.2 million in punitive damages.

Issue

May punitive damages be awarded in a private cause of action brought under § 202 of the ADA and § 504 of the Rehabilitation Act, whose remedies are tied to those available under Title VI?

Rule

Where a private damages action is authorized through Title VI remedies, punitive damages are not available. In Spending Clause legislation, a remedy counts as "appropriate relief" only if the funding recipient is on notice, by accepting federal funds, that it exposes itself to liability of that nature; recipients are generally on notice of remedies traditionally available for breach of contract, such as compensatory damages and injunctions, but not punitive damages.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

North River Transit Authority, a public transportation provider in Cleveland, receives federal transportation grants. After refusing to allow Maya Lopez, who uses a wheelchair, to board an accessible shuttle despite available space, the authority is sued under a federal disability statute whose private remedies are expressly the same as those available under Title VI.

If Maya proves intentional discrimination and seeks compensatory damages, an injunction, and punitive damages, which remedy is unavailable under the governing rule?

Explanation. Where a private suit proceeds through Title VI remedies, punitive damages are unavailable. The majority reasoned that Spending Clause statutes operate like contracts for notice purposes: recipients are generally on notice of traditional contract remedies such as compensatory damages and injunctions, but not punitive damages, which are generally unavailable for breach of contract and are of indeterminate magnitude. (Derived from Barnes v. Gorman (n.d.).)