Consolidated Rail Corp. v. Darrone

In Consolidated Rail Corp. v. Darrone, 465 U.S. 624 (1984), Conrail had refused to employ a locomotive engineer who had become disabled, although it did not find him unfit for employment. The engineer brought suit under 504 of the Rehabilitation Act. Conrail argued that 604 of Title VI limited employment discrimination actions to those employers who received federal financial assistance so long as the "primary object of the Federal financial assistance is to provide employment." 42 U.S.C. 2000d-3; see 465 U.S. at 628. Conrail argued that, because 504 incorporated Title VI, employment discrimination actions under the Rehabilitation Act were limited to those programs receiving funds "to provide employment" and, since the primary objective of the federal assistance received by Conrail was not to provide employment, the engineer could not bring suit under 504. The Court rejected Conrail's argument: It is clear that 504 itself contains no such limitation. Section 504 neither refers explicitly to 604 nor contains analogous limiting language; rather, that section prohibits discrimination against the handicapped under `any program or activity receiving Federal financial assistance.' And it is unquestionable that the section was intended to reach employment discrimination. 465 U.S. at 632 The Court in Consolidated Rail pointed to two facts: (1) 504 had a broad definition of covered programs, and (2) although 504 referred to Title VI, it did not refer "explicitly" to language in 604 that would have restricted its scope.