Barnes v. Gorman

Barnes v. Gorman, 536 U.S. 181 (2002), was a case decided by the Supreme Court of the United States on June 17, 2002. The court decided that punitive damages may not be awarded in private lawsuits brought under § 202 of the Americans with Disabilities Act of 1990 (ADA) and § 504 of the Rehabilitation Act.

Background
Gorman, a paraplegic, suffered serious injuries when he was transported to a Kansas City police station in a vehicle that was not equipped to accommodate people with disabilities. Gorman sued several police officials and officers for disability discrimination, in violation of § 202 of the ADA and § 504 of the Rehabilitation Act. At trial, a jury awarded Gorman compensatory and punitive damages. The District Court, however, vacated the jury award as to punitive damages, holding that such damages are not available in private lawsuits brought under the two statutes. The United States Court of Appeals for the Eighth Circuit reversed.

Decision
In a unanimous decision delivered by Justice Scalia, the Supreme Court held that punitive damages are not available under § 202 of the ADA and § 504 of the Rehabilitation Act, because remedies for private actions under these sections are coextensive with the remedies available under Title VI of the Civil Rights Act of 1964, under which punitive damages are not available in private suits.