Four federal statutes bar discrimination on the basis of race, gender, disability or other protected characteristics by recipients of federal financial assistance; namely Title VI and IX of the 1964 Civil Rights Act, the Rehabilitation Act and the Affordable Care Act. None of these acts expressly grant private rights of action to victims of discrimination that violates those Acts’ provisions. Yet, the US Supreme Court allowed implied rights of action for violation of those acts. Barnes v. Gorman (2002) 536 U. S. 181 held that punitive damages could not be recovered on a implied right of action under these statutes since the Acts were exercises of Congress’ power to spend and thus essentially contract provisions to which the recipients of federal financial assistance voluntarily bound themselves by accepting that assistance. Since punitive damages are not generally recoverable in contract actions, they are not recoverable under these Acts either. The same is true of emotional distress damages.