Richmond, VA (My Sportsbook) - A federal appeals court threw out a jury's $2 million award in a sex discrimination lawsuit filed by former Duke placekicker Heather Sue Mercer.

The case was brought before the 4th U.S. Circuit Court of Appeals where a three-judge panel came to the unanimous ruling that punitive damages are not available in private actions brought to enforce Title IX, the law that prohibits sex discrimination in education programs that receive federal funds.

Mercer made the Duke roster as a walk-on in 1995 but never played in a game. Before being cut prior to the 1996 season, Mercer claimed in her lawsuit that she was treated differently than the male members of the team. She stated that then-coach Fred Goldsmith would not let her dress for games or participate in scrimmages against Duke's first-string players.

The appeals court said the U.S. Supreme Court recently ruled that punitive damages may not be awarded in lawsuits filed under the Americans with Disabilities Act. Mercer cannot collect punitive damages because the ADA and Title IX are interpreted and applied in the same manner, the appeals court ruled.