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The Rehabilitation Act of 19731 (the "Rehabilitation Act" or the "Act") established a comprehensive federal plan aimed at improving the opportunities available to handicapped persons. Section 504,2 the central provision of the Act, prohibits discrimination against "otherwise qualified handicapped individuals ' 3 in programs or activities that receive federal financial assistance.4 Although section 504 does not explicitly establish a private right of action against discriminatory programs, 5 federal courts have uniformly agreed that an individual right of action is implied. 6 There has been much less agreement, however, on the question whether a compensatory damages remedy is available in an action

Safeguarding Equality for the Handicapped: Compensatory Relief under Section 504 of the Rehabilitation Act