Brief Fact Summary. The Respondents, Halderman and others (Respondents), filed suit against the Petitioners, the Pennhust State School and Hospital and its officials (Petitioners), charging conditions at the hospital violate class member’s rights. The Petitioners argued before the Supreme Court of the United States (Supreme Court) that the Eleventh Amendment of the United States Constitution (Constitution) prohibited the District Court from ordering state official to conform their conduct to state law.
Synopsis of Rule of Law. A federal court’s grant of relief against state officials on the basis of state law, whether, prospective or retroactive directly interferes with the principles of federalism that underlie the Eleventh Amendment of the Constitution.
The Court will not pass upon a constitutional question, although properly presented by the record, if there is also present some other ground upon which the case may be disposed of.View Full Point of Law
Issue. Whether a federal court has jurisdiction to award injunctive relief against state officials on the basis of state law?
Held. Federal Courts lack jurisdiction to enjoin Petitioners’ actions on the basis of state law. Reversed and remanded.
Dissent. The majority decision goes against established precedence by the Supreme Court, stating a federal court can award injunctive relief on the basis of state law. This new pronouncement will require federal courts to decide federal constitutional questions despite the availability of state-law grounds for decision.
Discussion. The Eleventh Amendment of the Constitution prohibits a state from being sued in federal courts by her own citizens, as well as by citizens of another state. The Eleventh Amendment bars a suit against state officials when the state is a real, substantial party in interest. An exception to the rule against suing state officials is when the suit is challenging the constitutionality of state official’s actions. When bringing suit in a federal court for a state official’s actions based on violation of federal law, a court can impose an injunction that governs the official’s future conduct, but may not award retroactive monetary relief. It is not the jurisdiction of federal courts to award relief against a state official based on state law.