Cummings v. Premier Rehab Keller, P.L.L.C.
The Facts
Jane Cummings, who is deaf and legally blind, alleged that Premier Rehab Keller violated the Rehabilitation Act and Affordable Care Act by refusing to provide an ASL interpreter. She sought emotional distress damages. The district court dismissed; the Fifth Circuit affirmed. The question was whether Spending Clause statutes permit emotional distress damages in private suits.
The Application
Cummings alleged disability discrimination under the Rehabilitation Act and Affordable Care Act, seeking emotional distress damages for Premier Rehab's refusal to provide an ASL interpreter. Under the Spending Clause framework, which treats federal funding statutes as contracts, Premier Rehab was bound only by conditions clearly disclosed in those statutes--and neither statute expressly authorized emotional distress damages, a remedy outside traditional contract law. Although Cummings's underlying claim for denial of services was viable, the Court held that emotional distress damages fell outside the scope of remedies Congress had clearly authorized for Spending Clause statutes. The result barred her recovery for emotional harm while preserving her access to other remedies like injunctive relief and compensatory damages for concrete harms.
The Conclusion
**Court ruled 6-3 for Premier Rehab.** Emotional distress damages are unavailable under Spending Clause statutes. Roberts wrote the majority; Breyer, Sotomayor, and Kagan dissented.
No circuit court data for this case.
Case Analysis
Overview
The Supreme Court held 6-3 that emotional distress damages are unavailable in private suits enforcing federal statutes enacted under Congress's Spending Clause, because funding recipients cannot fairly be said to have agreed to assume liability for such damages when they accepted federal funds.
Facts
Jane Cummings, who is deaf and legally blind, alleged that Premier Rehab Keller violated the Rehabilitation Act and Affordable Care Act by refusing to provide an ASL interpreter. She sought emotional distress damages. The district court dismissed; the Fifth Circuit affirmed. The question was whether Spending Clause statutes permit emotional distress damages in private suits.
Issue
Whether emotional distress damages are recoverable in a private action to enforce the Rehabilitation Act or the Affordable Care Act.
Rule
Spending Clause legislation functions as a contract; recipients are bound only by conditions they knowingly accept. Damages not traditionally available in contract -- including emotional distress -- are not recoverable unless Congress clearly authorized them.
Analysis
Cummings alleged disability discrimination under the Rehabilitation Act and Affordable Care Act, seeking emotional distress damages for Premier Rehab's refusal to provide an ASL interpreter. Under the Spending Clause framework, which treats federal funding statutes as contracts, Premier Rehab was bound only by conditions clearly disclosed in those statutes. And neither statute expressly authorized emotional distress damages, a remedy outside traditional contract law. Although Cummings's underlying claim for denial of services was viable, the Court held that emotional distress damages fell outside the scope of remedies Congress had clearly authorized for Spending Clause statutes. The result barred her recovery for emotional harm while preserving her access to other remedies like injunctive relief and compensatory damages for concrete harms.
Conclusion
**Court ruled 6-3 for Premier Rehab.** Emotional distress damages are unavailable under Spending Clause statutes. Roberts wrote the majority; Breyer, Sotomayor, and Kagan dissented.
Notes
OT2021. Added via SCOTUS bulk import 2026-05-14
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