Lane v. Peña

E494925

Lane v. Peña is a 1996 U.S. Supreme Court decision that clarified the strict standards for waiving federal sovereign immunity, holding that monetary damages against the United States must be expressly authorized by Congress.

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Lane v. Peña canonical 1

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Statements (47)

Predicate Object
instanceOf United States Supreme Court case
legal case
areaOfLaw United States federal courts
linked to: U.S. federal courts

administrative law
disability discrimination law
citation 116 S. Ct. 2092
135 L. Ed. 2d 486
518 U.S. 187
country United States
court Supreme Court of the United States
decisionDate 1996-06-20
dissentingJustices David H. Souter
John Paul Stevens
docketNumber 95-365
effect Limited the availability of monetary damages against the United States under the Rehabilitation Act.
Reaffirmed the requirement of an unequivocal textual waiver for federal sovereign immunity.
holding Section 504(a) of the Rehabilitation Act does not contain an unequivocal waiver of the Federal Government’s immunity from monetary damages.
The limited waiver of sovereign immunity in Section 505(a)(2) of the Rehabilitation Act applies only to federal funding recipients, not to the Federal Government as a funding provider.
Waivers of the Federal Government’s sovereign immunity to monetary damages must be unequivocally expressed by Congress.
issue Whether the Rehabilitation Act authorizes monetary damages against the Federal Government for violations of Section 504.
jurisdiction federal question jurisdiction
languageOfDecision English
legalSubject Rehabilitation Act of 1973
federal government liability
sovereign immunity
statutory interpretation
locationOfCourt Washington, D.C.
majorityJustices Anthony M. Kennedy
Antonin Scalia
Clarence Thomas
Ruth Bader Ginsburg
Sandra Day O’Connor
Stephen G. Breyer
William H. Rehnquist
majorityOpinionBy Justice Sandra Day O’Connor
petitioner Lane
precedentStatus binding on all lower federal courts in the United States
principle Any ambiguity in the scope of a waiver of sovereign immunity must be construed in favor of the sovereign.
Congress must speak with a clear voice when it intends to subject the United States to monetary liability.
relatedConcept sovereign immunity of the United States
waiver of sovereign immunity
respondent Federico F. Peña, Secretary of Transportation
Peña
statuteInterpreted Rehabilitation Act of 1973 §504
Rehabilitation Act of 1973 §505(a)(2)
term October Term 1995
vote 7-2

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