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Cummings v. Premier Rehab Keller

Docket: 20-219 Decision Date: 2022-04-28
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This links to the official slip opinion PDF.
How to read this page

Below are plain-language sections to help you understand what the Court decided in Cummings v. Premier Rehab Keller and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).

Summary

A short, plain-English overview of Cummings v. Premier Rehab Keller.

In Cummings v. Premier Rehab Keller, the Supreme Court addressed whether emotional distress damages are recoverable under the Rehabilitation Act of 1973 and the Affordable Care Act. The Court concluded that such damages are not available in private actions to enforce these statutes. The decision was based on the analogy to contract law, where emotional distress damages are generally not compensable.

Holding

The single most important “bottom line” of what the Court decided in Cummings v. Premier Rehab Keller.

The Court held that emotional distress damages are not recoverable in a private action to enforce either the Rehabilitation Act of 1973 or the Affordable Care Act.

Constitutional Concepts

These are the Constitution-related themes that appear in Cummings v. Premier Rehab Keller. Click a concept to see other cases that involve the same idea.

  • Why Spending Power is relevant to Cummings v. Premier Rehab Keller

    The case primarily deals with Congress's authority under the Spending Clause to set conditions on federal funding and the implications of those conditions for remedies available under federal statutes.

    Syllabus excerpt (verbatim)
    Congress has broad power under the Spending Clause of the Constitution to 'fix the terms on which it shall disburse federal money.'
  • Why Remedies and Relief is relevant to Cummings v. Premier Rehab Keller

    The Court's decision focuses on the types of remedies available under the Spending Clause statutes, specifically whether emotional distress damages are recoverable.

    Syllabus excerpt (verbatim)
    Emotional distress damages are not recoverable in a private action to enforce either the Rehabilitation Act of 1973 or the Affordable Care Act.
  • Why Procedural Due Process is relevant to Cummings v. Premier Rehab Keller

    The case indirectly involves considerations of procedural fairness in terms of the notice given to funding recipients about the liabilities they might incur by accepting federal funds.

    Syllabus excerpt (verbatim)
    A particular remedy is available in a private Spending Clause action 'only if the funding recipient is on notice that, by accepting federal funding, it exposes itself to liability of that nature.'

Key Quotes

Short excerpts from the syllabus in Cummings v. Premier Rehab Keller that support the summary and concepts above.

  • Emotional distress damages are not recoverable in a private action to enforce either the Rehabilitation Act of 1973 or the Affordable Care Act.
  • Congress has broad power under the Spending Clause of the Constitution to 'fix the terms on which it shall disburse federal money.'
  • A particular remedy is available in a private Spending Clause action 'only if the funding recipient is on notice that, by accepting federal funding, it exposes itself to liability of that nature.'

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