This educational guide is based on the linked primary sources. It is not a Court publication, is not affiliated with the Court, and is not legal advice.
In brief
Overview
The case concerns whether a private plaintiff can obtain punitive damages against municipal government defendants under Section 504 of the Rehabilitation Act and Title II of the Americans with Disabilities Act.
According to Robbins, petitioners argue that punitive damages are available against governmental entities because Title II is silent and thus permits an unlimited punitive‑damages remedy.
According to United States, as amicus curiae (Gregory G. Garre), according to United States, as amicus curiae (Gregory G. Garre), the statutes do not sanction punitive damages, which exceed what is necessary to make good a wrong.
The Court notes that Congress intended the same remedies for states as for private entities, and that punitive damages serve a deterrent purpose.
The Court also states that policies are not served by immunizing defendants from punitive damages under a Newport rationale.
- [1] 8838f9ed96cc413714e6-r1-12cc86e3b7db2203.pdf, p. 3
- [2] 8838f9ed96cc413714e6-r1-12cc86e3b7db2203.pdf, p. 36
- [3] 8838f9ed96cc413714e6-r1-12cc86e3b7db2203.pdf, p. 43
- [4] 8838f9ed96cc413714e6-r1-12cc86e3b7db2203.pdf, p. 44
- [5] 8838f9ed96cc413714e6-r1-12cc86e3b7db2203.pdf, p. 16
- [6] 8838f9ed96cc413714e6-r1-12cc86e3b7db2203.pdf, p. 36
- [7] 8838f9ed96cc413714e6-r1-12cc86e3b7db2203.pdf, p. 37
- [8] 8838f9ed96cc413714e6-r1-12cc86e3b7db2203.pdf, p. 38
Background and question before the Court
Justice Breyer asked, “What are we supposed to do then?”
According to Justice (unspecified), according to Justice (unspecified), an unspecified justice questioned reliance on “heavy gun” statutes such as Title VI and Title IX, noting they are rarely used.
Chief Justice asked about recent cases (Alexander, Malesko) indicating a more critical look at these claims.
What each side argues
Petitioner Position
According to Lawrence S. Robbins (Petitioners), according to Lawrence S. Robbins (Petitioners), petitioners assert that a private plaintiff may obtain punitive damages against municipal defendants under Section 504 and Title II.
According to Robbins, petitioners argue that the 1991 amendment limited punitive damages to nongovernmental entities, but Title II’s silence permits an unlimited punitive‑damages remedy against governmental entities.
Respondent Position
Source-limited. The record does not yet support a complete account.
What happened at oral argument
Justice Breyer asked, “What are we supposed to do then?”
According to Justice (unspecified), according to Justice (unspecified), an unspecified justice questioned reliance on “heavy gun” statutes such as Title VI and Title IX, noting they are rarely used.
Chief Justice asked about recent cases (Alexander, Malesko) indicating a more critical look at these claims.
What the Court decided
Why it matters
If punitive damages are available against government entities, they can serve as a deterrent to discrimination, aligning with Congress’s goal of eliminating disability discrimination.
The parties present competing interpretations of whether the statutes expressly permit punitive damages.
Terms to know
No glossary terms are available for this guide.
Primary sources
Read the source materials on the official site or open the immutable repository copy used for this guide.
- 8838f9ed96cc413714e6-r1-12cc86e3b7db2203.pdforal argument transcript
Guide generated September 19, 2026. Automated validation accepted this version.