Lane v. Pena

Summary

The Court, in an opinion by Justice O'Connor joined by Chief Justice Rehnquist and Justices Scalia, Kennedy, Souter, Thomas, and Ginsburg, held that Congress had not unequivocally waived federal sovereign immunity from monetary damages for violations of § 504(a) of the Rehabilitation Act by Executive agencies conducting their own programs. Neither the Act's remedies provision nor the 1986 provision addressing state immunity supplied the necessary unambiguous waiver. The Court therefore affirmed the denial of compensatory damages to Lane. Justice Stevens, joined by Justice Breyer, dissented, arguing that the statutory text, historical context, and legislative history demonstrated congressional intent to authorize damages against federal agencies and that the majority's stringent interpretive rules frustrated that intent.