## Facts

- James Griffin Lane enrolled as a midshipman at the United States Merchant Marine Academy after satisfying appointment and medical requirements.
- During his first year, Lane was diagnosed with diabetes mellitus and reported the condition to the Academy.
- The Academy concluded Lane had insulin-dependent diabetes and separated him as medically disqualified, making him ineligible for certain commissions.
- Lane sued federal transportation officials and related federal entities, alleging disability discrimination in violation of Rehabilitation Act § 504(a), which bars discrimination in programs conducted by executive agencies.
- Lane sought reinstatement, compensatory damages, attorney’s fees, and costs.

## Issues

1. Whether Congress unequivocally waived the Federal Government’s sovereign immunity to authorize monetary damages for violations of Rehabilitation Act § 504(a) by federal executive agencies.
2. Whether Rehabilitation Act § 505(a)(2), incorporating Title VI “remedies, procedures, and rights” for certain § 504 claims, extends damages remedies to § 504(a) claims involving programs conducted by executive agencies.

## Decision

- The Supreme Court affirmed the denial of compensatory damages against the Federal Government for the § 504(a) violation.
- The Court held that sovereign immunity bars monetary awards against the United States unless Congress clearly and unequivocally waives immunity in statutory text.
- The Court concluded that § 505(a)(2) does not unambiguously authorize damages against federal executive agencies for discrimination in programs they conduct.
- Lane could obtain equitable relief (including reinstatement), but not compensatory damages, under § 504(a) against the federal government.

## Legal Principles

- A waiver of federal sovereign immunity must be unequivocally expressed in the statutory text and is strictly construed in favor of the United States.
- Rehabilitation Act § 505(a)(2)’s incorporation of Title VI remedies for acts by a “recipient of Federal assistance” or “Federal provider of such assistance” does not clearly cover discrimination in “program[s] or activit[ies] conducted by any Executive agency.”
- Courts will not infer a damages waiver from statutory purpose, remedial cross-references, or general “all appropriate remedies” presumptions where sovereign immunity is implicated.
- Related provisions that explicitly specify remedies against the federal government in other contexts support the inference that Congress speaks with precision when it intends to permit damages suits against the United States.
- The 1986 amendment addressing state immunity does not supply a waiver of the Federal Government’s immunity for damages under § 504(a).

## Conclusion

The Court held that § 504(a) of the Rehabilitation Act does not authorize compensatory damages against federal executive agencies because Congress did not clearly waive federal sovereign immunity for such monetary relief, leaving equitable remedies as the available relief.


Lane v. Peña, 518 U.S. 187 (1996)