Cummings v. Premier Rehab Keller
View Official PDFBelow 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.
The Supreme Court decided that emotional distress damages are not recoverable in private actions under the Rehabilitation Act of 1973 or the Affordable Care Act. The Court emphasized that funding recipients must have clear notice of potential liabilities when accepting federal funds. This decision aligns with the Court's interpretation of Spending Clause statutes as contracts between the government and funding recipients.
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.
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Why Spending Power is relevant to Cummings v. Premier Rehab Keller
The case revolves around Congress's power under the Spending Clause to set conditions on federal funding, which is central to the Court's analysis.
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.'
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Why Remedies and Relief is relevant to Cummings v. Premier Rehab Keller
The Court's decision focuses on the availability of emotional distress damages as a remedy under Spending Clause statutes.
Syllabus excerpt (verbatim)Held: Emotional distress damages are not recoverable in a private action to enforce either the Rehabilitation Act of 1973 or the Affordable Care Act.
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Why Procedural Due Process is relevant to Cummings v. Premier Rehab Keller
The Court discusses the notice required for funding recipients regarding the liabilities they assume, which relates to due process considerations.
Syllabus excerpt (verbatim)The Court thus presumes that recipients are aware that they may face the usual contract remedies in private suits brought to enforce their Spending Clause 'contract' with the Federal Government.
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.'
