In a unanimous opinion written by Justice Scalia, the Court held that the TCA provided the exclusive remedy for the plaintiff. The fact that the TCA did not provide for attorneys fees and included a 30-day statute of limitations were cited as evidence that Congress did not intend that enforcement under § 1983 - with its longer statute of limitation and provision for attorneys fees - be available. The Court reached this decision despite the existence of a "savings clause," providing that the TCA should not "modify, impair or supersede" federal law. It concluded that § 1983 was not impaired - it would operate just as it did before the TCA was enacted.
For more details about this case and others, see the Spring 2005 issue of NHeLPs Health Advocate newsletter (subscription-only).