Summary of Pennhurst State School & Hospital v. Halderman
465 U. S. 89 (1984)
11th AMENDMENT-ENFORCE FED RIGHTS IN SUITS AGAINST STATE OFFICERS
Facts: Respondent Halderman, a resident of petitioner Pennhurst State School and Hospital. Pennh is a hospital that cares for the mentally retarded. Conditions at Pennh are not only dangerous, with the residents often physically abused or drugged by staff members, but also inadequate for the ‘habilitation’ of the retarded. Indeed, the court found that the physical, intellectual, and emotional skills of some residents have deteriorated at Penn. Suit alleged Pennh. violated various federal constitutional and statutory rights of the class members as well as their rights under the Penn Mental Health and Mental Retardation Act of 1966 (MH/MR Act). Ultimately, the District Court awarded injunctive relief based in part on the Act, which was held to provide a right to adequate habilitation.
Issue: Whether Petitioner violated the state law in carrying out their official duties at Pennhurst and in doing so, is a violation against the State and therefore barred by the 11th Amnedment?
Holding: Judgment could not be upheld against county officials on basis of their state law obligations where any relief granted against county officials alone on basis of state statute would be partial and incomplete at best.
Procedure: Class action was brought by mentally retarded citizens D Ct judgment for PL, (damages and injunctive relief were sought), and DF, (various state and local officials and institutions), appealed. Ct of App, substantially affirmed, and certiorari was granted. The S Ct, reversed and remanded. On remand, the Ct of App, affirmed its prior judgment in its entirety. Certiorari was granted. Reversed and remanded.
Rule: The Judicial Power of the United States shall not be construed to extend to any suit in law or equity, commenced or prosecuted against one of the United States by Citizens of another State, or by Citizens or Subjects of any Foreign State.
Ct. Majority: When a suit is brought against a state official, it is brought against the State itself. Whether the parties are seeking injunctive relief or actual damages before a Fed. Ct., a suit against state officials on the basis of state law, cannot be entertained. The state is the real and substantial party at interest, and therefor, the state immunity under the 11th is preserved.
Minority: Petitioner’s conduct was prohibited by state law, and the protections of sovereign immunity do not extend to them. Conduct that exceeds the scope of an official’s legal discretion is not conduct the sovereign has authorized.
PL A :(Resp) The suit is not against the State and only seeks injunctive relief against future instances and financial relief. The state officials violated state and federal constitutions.
Def A: (Pet) 11th Amendment prohibits Fed. D. Ct. from ordering State officials to conform their conduct to state law.
Notes to Case
S. Ct held that: (1) Eleventh Amendment prohibited federal district court from ordering state officials to conform their conduct to state law with respect to conditions of confinement at institution, since the state was a real, substantial party in interest; (2) Eleventh Amendment barred state law claims brought in district court under pendent jurisdiction; were 11th Amendment challenges that had been settled.
[Young] Rule-If conduct is not permitted by the sovereign then it is not attributable to the sovereign under the immunity principle of the 11th Amendment or Federalism. Injunctive relief is allowed where an official who acts unconstitutionally is “stripped of his official character."
[Edelman] Rule- A suit against state officials for retroactive monetary relief, whether based on federal or state law, must be brought in a state court.
Pendent jurisdiction: The principle that allows state created causes of action arising out of the same transaction to be joined with a federal cause of action even if diversity is not present.