Your feedback ensures we stay focused on the facts that matter to you most—take our survey

Cummings v. Premier Rehab Keller, P.L.L.C.

From Ballotpedia
Revision as of 19:07, 3 April 2023 by Samantha Post (contribs) (Text replacement - "===Dissenting===" to "===Dissenting opinion===")
(diff) ← Older revision | Latest revision (diff) | Newer revision → (diff)
Jump to: navigation, search

Supreme Court of the United States
Cummings v. Premier Rehab Keller, P.L.L.C.
Term: 2021
Important Dates
Argued: November 30, 2021
Decided: April 28, 2022
Outcome
affirmed
Vote
6-3
Majority
Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett
Concurring
Brett Kavanaugh • Neil Gorsuch
Dissenting
Stephen Breyer • Sonia Sotomayor • Elena Kagan

Cummings v. Premier Rehab Keller, P.L.L.C. is a case that was decided by the Supreme Court of the United States on April 28, 2022, during the court's October 2021-2022 term. The case was argued before the court on November 30, 2021,

The court affirmed the decision of the United States Court of Appeals for the 5th Circuit in a 6-3 ruling, holding emotional distress damages are not recoverable in private lawsuits brought under the Rehabilitation Act of 1973 and the Affordable Care Act. Chief Justice John Roberts delivered the majority opinion of the court. Justice Brett Kavanaugh concurred, joined by Justice Neil Gorsuch. Justice Stephen Breyer filed a dissenting opinion, joined by Justices Sonia Sotomayor and Elena Kagan.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The case: Jane Cummings, who is legally blind and was born deaf, communicates primarily through American Sign Language (ASL). Cummings contacted physical therapy services provider Premier Rehab Keller, P.L.L.C. ("Premier") to treat her chronic back pain. She requested that Premier provide an ASL interpreter. Premier denied her request. Cummings filed a lawsuit in U.S. district court against Premier for disability discrimination, alleging that the company violated federal anti-discrimination laws when it refused to provide her with an ASL interpreter. Cummings sought equitable relief and compensatory damages for emotional distress. The district court granted Premier's motion to dismiss and the U.S. Court of Appeals for the 5th Circuit affirmed the judgment. Click here to learn more about the case's background.
  • The issue: The case concerned federal disability laws and whether they allow the petitioner to be awarded compensatory damages for emotional distress.
  • The questions presented: "Whether the compensatory damages available under Title VI and the statutes that incorporate its remedies include compensation for emotional distress."[2]
  • The outcome: The court affirmed the decision of the United States Court of Appeals for the 5th Circuit in a 6-3 ruling, holding emotional distress damages could not be recovered in a private lawsuit alleging violations of the Rehabilitation Act of 1973 and the Affordable Care Act.[1]


    • The case came on a writ of certiorari to the United States Court of Appeals for the 5th Circuit.[3] To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    • April 28, 2022: The U.S. Supreme Court affirmed the decision of the 5th Circuit.
    • November 30, 2021: The U.S. Supreme Court heard oral argument.
    • July 2, 2021: The U.S. Supreme Court agreed to hear the case.
    • August 21, 2020: Jane Cummings appealed to the U.S. Supreme Court.
    • January 24, 2020: The 5th Circuit affirmed the district court's judgment.

    Background

    When the suit was decided, Jane Cummings was legally blind and had been deaf since her birth. Her primary communication method was American Sign Language (ASL). Premier Rehab Keller, P.L.L.C. ("Premier") was a company that provided physical therapy services. Premier received federal funding. In 2016, Cummings contacted Premier to treat her chronic back pain and requested that Premier provide an ASL interpreter. Premier refused her request and told Cummings that she could communicate with the therapist using written notes, gesturing, lipreading, or she could bring her own ASL interpreter. Cummings told Premier that she couldn't use those methods and she contacted a different provider.[3][4]

    Cummings filed a lawsuit in U.S. district court against Premier for disability discrimination, alleging that the company violated federal anti-discrimination laws when it refused to provide her with an ASL interpreter. Cummings sought equitable relief and compensatory damages for emotional distress under the Americans with Disabilities Act, the Rehabilitation Act, the Patient Protection and Affordable Care Act (ACA), and the Texas Human Resources Code. Premier moved to dismiss for lack of subject matter jurisdiction and for failure to state a claim upon which relief could be granted. In response, Cummings withdrew her state law claim. The district court granted the motion to dismiss, ruling that while Cummings had standing, she failed to state a claim for damages under any of the cited statutes, and failed to allege facts supporting her equitable relief claim. The court held that the only compensable injuries that Cummings alleged were "humiliation, frustration, and emotional distress."[3][4]

    On appeal, the U.S. Court of Appeals for the 5th Circuit affirmed the district court's judgment.[3] Cummings appealed to the U.S. Supreme Court on August 21, 2020, and the court granted review in the case on July 2, 2021.[2]

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Whether the compensatory damages available under Title VI and the statutes that incorporate its remedies include compensation for emotional distress.[5] ”

    Oral argument

    The U.S. Supreme Court heard oral argument on November 30, 2021.

    Audio

    Audio of oral argument:[6]



    Transcript

    Transcript of oral argument:[7]

    Outcome

    In a 6-3 opinion, the court affirmed the decision of the United States Court of Appeals for the 5th Circuit, holding that emotional distress damages were not recoverable in private lawsuits alleging violations of the Rehabilitation Act of 1973 or the Affordable Care Act.[1] Chief Justice John Roberts delivered the majority opinion of the court. Justice Brett Kavanaugh concurred, joined by Justice Neil Gorsuch. Justice Stephen Breyer filed a dissenting opinion, joined by Justices Sonia Sotomayor and Elena Kagan.

    Opinion

    In the court's majority opinion, Chief Justice Roberts wrote:[1]

    “

    In order to decide whether emotional distress damages are available under the Spending Clause statutes we consider here, we therefore ask a simple question: Would a prospective funding recipient, at the time it “engaged in the process of deciding whether [to] accept” federal dollars, have been aware that it would face such liability? Arlington, 548 U.S., at 296. If yes, then emotional distress damages are available; if no, they are not. ...

    It is hornbook law that "emotional distress is generally not compensable in contract." ... It follows that such damages are not recoverable under the Spending Clause statutes we consider here. ...

    For the foregoing reasons, we hold that emotional distress damages are not recoverable under the Spending Clause antidiscrimination statutes we consider here. The judgment of the Court of Appeals is affirmed.[5]

    		”
    —Chief Justice Roberts

    Concurring opinion

    Justice Kavanaugh filed a concurring opinion, joined by Justice Gorsuch.

    In his concurring opinion, Justice Kavanaugh wrote about the way compensatory damages for emotional distress are analyzed:[1]

    “

    In analyzing whether compensatory damages for emotional distress are available under the implied Title VI cause of action, both the Court and the dissent ably employ the contract-law analogy set forth by this Court’s precedents. ... Instead of continuing to rely on that imperfect analogy, I would reorient the inquiry to focus on a background interpretive principle rooted in the Constitution’s separation of powers. Congress, not this Court, creates new causes of action. ... In my view, that background interpretive principle—more than contract-law analysis—counsels against judicially authorizing compensatory damages for emotional distress in suits under the implied Title VI cause of action.[5]

    		”
    —Justice Kavanaugh

    Dissenting opinion

    Justice Breyer filed a dissenting opinion, joined by Justices Sotomayor and Kagan.

    In his dissent, Justice Breyer wrote:[1]

    “

    The Court has asked the right question: “[W]ould a prospective funding recipient, at the time it engaged in the process of deciding whether to accept federal dollars, have been aware that it would face such liability?” Ante, at 5 (internal quotation marks and alterations omitted). And it has correctly observed that our precedents instruct us to answer this question by drawing an analogy to contract law. But I disagree with how the Court has applied that analogy. ... The Spending Clause statutes before us prohibit intentional invidious discrimination. That kind of discrimination is particularly likely to cause serious emotional disturbance. Thus, applying our precedents’ contract analogy, I would hold that victims of intentional violations of these antidiscrimination statutes can recover compensatory damages for emotional suffering. I respectfully dissent. [5]

    		”
    —Justice Breyer

    Text of the opinion

    Read the full opinion here.

    October term 2021-2022

    See also: Supreme Court cases, October term 2021-2022

    The Supreme Court began hearing cases for the term on October 4, 2021. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[8]

    The court agreed to hear 68 cases during its 2021-2022 term.[9] Four cases were dismissed and one case was removed from the argument calendar.[10]

    The court issued decisions in 66 cases during its 2021-2022 term. Three cases were decided without argument. Between 2007 and 2021, SCOTUS released opinions in 1,128 cases, averaging 75 cases per year.


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 Supreme Court of the United States, Cummings v. Premier Rehab Keller - "Opinion," accessed April 28, 2022
    2. ↑ 2.0 2.1 2.2 U.S. Supreme Court, "Cummings v. Premier Rehab Keller, P.L.L.C.: On Petition for a Writ of Certiorari to the United States Court of Appeals for the Fifth Circuit," filed August 21, 2020
    3. ↑ 3.0 3.1 3.2 3.3 United States Court of Appeals for the 5th Circuit, Cummings v. Premier Rehab Keller, P.L.L.C., decided January 24, 2020
    4. ↑ 4.0 4.1 SCOTUSblog, "Justices add one religious-rights case to docket but turn down another," July 2, 2021
    5. ↑ 5.0 5.1 5.2 5.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued November 30, 2021
    7. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued November 30, 2021
    8. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed February 4, 2021
    9. ↑ Consolidated cases are counted as one case for purposes of this number.
    10. ↑ U.S. Supreme Court, "Order List: 593 U.S.," May 17, 2021
    Retrieved from "https://ballotpedia.org/wiki/index.php?title=Cummings_v._Premier_Rehab_Keller,_P.L.L.C.&oldid=9117284"