In the case of Universities Research Association, Inc. v. Coutu (1980), the United States Supreme Court ruled that an employee could not seek damages for emotional distress under Section 301 of the Labor Management Relations Act (LMRA). The plaintiff, Richard Coutu, was a former employee of Universities Research Association who claimed he had been wrongfully terminated and suffered emotional distress as a result. He sought to recover these damages under Section 301 which allows employees to sue their employers for breaches of collective bargaining agreements. However, the court held that this section only provides remedies for contractual violations and does not cover personal injury claims such as emotional distress. Therefore, it concluded that Mr.Coutu's claim was outside its jurisdiction.

In the dissenting opinion for UNIVERSITIES RESEARCH ASSN., INC. v. COUTU, 1980, Justice Brennan disagreed with the majority's interpretation of Section 504 of the Rehabilitation Act of 1973 and its application to this case. He argued that Congress intended a broader scope for Section 504 than just prohibiting discrimination against disabled individuals by federal contractors or subcontractors in their employment practices; it also aimed to prevent such entities from discriminating against disabled persons in any aspect related to their operations if they received federal financial assistance. Therefore, he believed that Universities Research Association (URA), as a recipient of federal funds, should be held accountable under Section 504 regardless whether Mr.Coutu was an employee or not because URA denied him access based on his disability status which is contrary to what Congress intended when enacting this law.