Barnes v. Gorman

PETITIONER: Barnes
RESPONDENT: Gorman
LOCATION: Los Angeles City Hall

DOCKET NO.: 01-682
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Eighth Circuit

CITATION: 536 US 181 (2002)
ARGUED: Apr 23, 2002
DECIDED: Jun 17, 2002

ADVOCATES:
Gregory G. Garre - Argued the cause for the United States, as amicus curiae, supporting the petitioners
Jeffrey Robert White - for the Association of Trial Lawyers of America et al. as amici curiae urging affirmance
Lawrence S. Robbins - Argued the cause for the petitioners
Scott L. Nelson - Argued the cause for the respondent

Facts of the case

Jeffrey Gorman is a paraplegic. After being arrested, he was transported to a Kansas City police station in a van that was not equipped to accommodate the disabled. Gorman was removed from his wheelchair and seatbelted to a bench in the van. During the ride, Gorman fell to the floor, suffering serious injuries that left him unable to work full time. Gorman sued certain Kansas police officials for discriminating against him on the basis of his disability, in violation of the Americans with Disabilities Act of 1990 (ADA) and the Rehabilitation Act of 1973, by failing to maintain appropriate policies for the arrest and transportation of persons with spinal cord injuries. A jury awarded him compensatory and punitive damages. The District Court vacated as to punitive damages, holding that they are unavailable in private suits brought under the ADA and the Rehabilitation Act. In reversing, the Court of Appeals found punitive damages available under a general rule that absent clear direction to the contrary by Congress federal courts have the power to award any appropriate relief for violation of a federal right.

Question

May punitive damages be awarded in a private cause of action brought under the Americans with Disabilities Act of 1990 and the Rehabilitation Act of 1973?

Media for Barnes v. Gorman

Audio Transcription for Oral Argument - April 23, 2002 in Barnes v. Gorman

Audio Transcription for Opinion Announcement - June 17, 2002 in Barnes v. Gorman

William H. Rehnquist:

The opinion of the Court in No. 01-682 Barnes against Gorman will be announced by Justice Scalia.

Antonin Scalia:

Court of Appeals for the Eighth Circuit.

The respondent is a paraplegic who suffered serious injuries when after being arrested he was transported to a Kansas City police station in a van that was not equipped to accommodate wheelchairs. He sued petitioner police officers and other officials for discriminating against him on the basis of his disability in violation of Section 202 of the Americans with Disabilities Act of 1990, and Section 504 of the Rehabilitation Act of 1973 by failing to maintain appropriate policies for the arrest and transportation of persons with spinal cord injuries.

A jury awarded him compensatory and punitive damages, but the District Court vacated as to the punitive holding that they are unavailable in private suits brought under Section 202 and Section 504.

In reversing, the Eighth Circuit found punitive damages available under the general rule of one of our cases called Franklin versus Gwinnett County Public Schools which stated that “absent clear direction to the contrary by Congress, the Federal Courts have the power to award any appropriate relief for violation of a federal right.

We granted certiorari and we now reverse.

Section 2 of the Americans with Disabilities Act prohibits discrimination against the disable by public entities.

Section 504 of the Rehabilitation Act prohibits discrimination against the disabled by recipients of federal fundings including private organizations.

Both sections are enforceable through private causes of action and the statutes say that the remedies available are those available in a private action under Title VI of the Civil Rights Act of 1964.

So, that shifts our whole case over to Title VI. Title VI invokes Congress’ spending clause power to place conditions on the grant of federal funds.

This Court has regularly applied a contract clause analogy in defining the scope of conduct for which funding recipients may be held liable in money damages and in finding a damages’ remedy available for private suits.

The same analogy applies, we think, in determining the scope of damages’ remedies. Under spending clause legislation, a remedy is appropriate relief only if the recipient is on notice that by accepting federal funding, it exposes itself to such liability, and a funding recipient is generally on notice that it is subject only to those remedies explicitly provided in the relevant legislation and to those traditionally available in breach of contract suits.

Since Title VI mentions no remedies and since punitive damages are generally not available for breach of contract, punitive damages are not available under Title VI.

Nor could it be said that Title VI funding recipients have by merely accepting the funds implicitly consented to a remedy which is not normally available for contract actions in the indetermitent magnitude of which could produce liablity far exceeding the level of federal funding that they have accepted.

To make the final connection, since punitive damages may not be awarded in private suits brought under Title VI, it follows that they may not be awarded in suits brought under Section 202 of the ADA and Section 504 of the Rehabilitation Act.

Justice Souter has filed a concurring opinion in which Justice O’Connor has joined; Justice Stevens has filed an opinion concurring in the judgment in which Justices Ginsburg and Breyer have joined.

Sarah from Law Aspect

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