Id. See Restatement (Second) of Contracts § 357, at 163 (Availability of Specific Performance and Injunction); 3 Williston on Contracts § 1445-1450 (1920). I. THE 2002 SUPREME COURT DECISION IN BARNES V. GORMAN INSTRUCTS THAT INDETERMINATE DAMAGES, SUCH AS PUNITIVE DAMAGES, ARE INAPPROPRIATE REMEDIES IN CASES ARISING FROM SPENDING CLAUSE LEGISLATION. The Supreme Court case of Barnes v. Gorman, addressing the issues of punitive damages, identified the analytical model for questions involving damages of an indeterminate magnitude. In 2002, the Barnes v. Gorman court, applying contract principles, deemed an award for punitive damages an inappropriate form of relief in a suit based upon the ADA, the Rehabilitation Act, and Title VI. See Barnes v. Gorman, 536 U.S. at 189, 122 S.Ct. 2097 (<HOLDING>). Relying on traditional contract law
holding that title ii ada suits and rehabilitation act suits for prospective injunctive relief may be brought under ex parte young against state officers in their official capacities holding that punitive damages may not be awarded  in suits brought under  202 of the ada and  504 of the rehabilitation act holding that the same standards apply to claims under the ada and under the rehabilitation act holding the ada and the rehabilitation act applicable holding that exemption under the ada does not preclude liability under the rehabilitation act