Lane v. Pena

518 U.S. 187 (1996)

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Lane v. Pena

United States Supreme Court
518 U.S. 187 (1996)

  • Written by Alexander Hager-DeMyer, JD

Facts

James Lane (plaintiff) was a first-year student at the United States Merchant Marine Academy (academy), an officer-training service academy administered by the Department of Transportation. Lane was diagnosed with diabetes mellitus and reported the diagnosis to the academy’s chief medical officer. Lane was separated from the academy because his insulin-dependent diabetes constituted a disqualifying condition that made him ineligible for commissioning as an officer. Lane filed suit in federal district court against the Department of Transportation secretary and other administrators (government) (defendants), arguing that the separation violated § 504(a) of the Rehabilitation Act. The district court ruled in favor of Lane, granting Lane a reinstatement into the academy and compensatory damages. The government appealed the compensatory damages to the District of Columbia Circuit, claiming that the United States had sovereign immunity and was protected against monetary damages under §§ 504(a) and 505(a)(2). The appellate court denied Lane’s compensatory damages because it found that §§ 504(a) and 505(a)(2) did not contain any statutory text indicating that Congress waived its sovereign immunity. Lane appealed to the United States Supreme Court.

Rule of Law

Issue

Holding and Reasoning (O’Connor, J.)

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