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

Cummings v. Premier Rehab Keller, P.L.L.C., 596 U.S. ___ (2022), was a United States Supreme Court case related to the Rehabilitation Act of 1973 and the Affordable Care Act.

Cummings v. Premier Rehab Keller, P.L.L.C.
Argued November 30, 2021
Decided April 28, 2022
Full case nameJane Cummings v. Premier Rehab Keller, P.L.L.C.
Docket no.20-219
Citations596 U.S. ___ (more)
ArgumentOral argument
Holding
Emotional distress damages are not recoverable in a private action to enforce either the Rehabilitation Act of 1973 or the Affordable Care Act.
Court membership
Chief Justice
John Roberts
Associate Justices
Clarence Thomas · Stephen Breyer
Samuel Alito · Sonia Sotomayor
Elena Kagan · Neil Gorsuch
Brett Kavanaugh · Amy Coney Barrett
Case opinions
MajorityRoberts, joined by Thomas, Alito, Gorsuch, Kavanaugh, Barrett
ConcurrenceKavanaugh, joined by Gorsuch
DissentBreyer, joined by Sotomayor, Kagan
Laws applied
Rehabilitation Act of 1973
Affordable Care Act

Background

Jane Cummings is deaf and legally blind. American Sign Language is her primary method of communication. In 2018, she sued Premier Rehab Keller, a company that offers physical therapy, under the Rehabilitation Act of 1973 and the Affordable Care Act for not providing her an ASL interpreter. She sought damages for emotional distress. The United States District Court for the Northern District of Texas dismissed her complaint, holding neither law allows people to recover damages for emotional distress. The United States Court of Appeals for the Fifth Circuit affirmed. Cummings filed a petition for a writ of certiorari.[1]

Supreme Court

Certiorari was granted in the case on July 2, 2021. Oral arguments were held on November 30, 2021. On April 28, 2022, the Supreme Court affirmed the Fifth Circuit in a 6–3 decision, with Chief Justice John Roberts writing the majority, and Justice Stephen Breyer writing the dissent. Because the structure of Title VI of the Civil Rights Act of 1964 is similar to the Rehabilitation Act and the ACA, this decision means people cannot recover emotional distress damages under that statute, either.

References

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