Consolidated Rail Corporation v. Darrone

Background

A railroad company created by federal law (Consolidated Rail Corporation, or Conrail) received large federal payments and sold the United States billions of dollars in securities. Thomas LeStrange, a former locomotive engineer who lost his left hand and forearm in an earlier accident, sued after Conrail refused to rehire him. He relied on section 504 of the Rehabilitation Act, which bars discrimination by programs that receive federal financial assistance. Lower courts disagreed about whether a private suit under section 504 is allowed when the federal aid’s primary purpose was not to provide employment.

Reasoning

The Court addressed whether section 504 incorporates Title VI’s special rule that employment claims are actionable only when federal aid’s “primary objective” is to provide employment. The majority concluded that section 504’s plain language, its legislative history, and the implementing federal regulations support a broader reading. Congress’s 1978 amendment made Title VI remedies available to section 504 plaintiffs but did not import the Title VI “primary objective” limitation. The Court also held that a plaintiff alleging intentional discrimination may recover backpay as equitable relief. The Court did not decide whether the specific hiring decision occurred within a particular “program or activity” that actually received federal assistance; that factual issue remains for later proceedings.

Real world impact

The decision lets disabled job applicants bring employment-discrimination suits against recipients of federal funds even if the funds were not primarily meant to create jobs. It also confirms that victims who prove intentional discrimination can seek past pay. Because the Court left program-specific facts unresolved, lower courts must still determine in each case whether the particular program received federal aid.