Pennhurst State School & Hospital v. Halderman

Citation. 465 U.S. 89, 104 S.Ct. 900, 79 L.Ed.2d 67 (1984)

Brief Fact Summary.

Halderman alleged that the School violated the rights of those institutionalized there.  Specifically, the complaint alleged that the School violated the Eighth and Fourteenth Amendments as well as several state and federal statutes.

Synopsis of Rule of Law.

The Eleventh Amendment prevents a citizen from suing a State directly, but a citizen can sue a state official for injunctive relief when that official acts either in an unconstitutional manner or contrary to federal law.  However, the Eleventh Amendment completely bars litigants from suing a State or state officials over violations of state law in federal court.

Facts.

Halderman complained that the School violated the rights of those institutionalized there.  In the complaint, Halderman alleged that the School violated the Eighth and Fourteenth Amendments as well as several state and federal statutes.  The Court of Appeals for the Third Circuit held that a state statute enabled the claim and rejected the argument that the Eleventh Amendment barred federal courts from hearing the case.  The Supreme Court reversed the Third Circuit and remanded it for the court to decide if the claims seeking injunctive relief had merit.  On remand, the Third Circuit again held that the state statute supported its prior holding, so it did not reach the federal questions.  The case then reached the Supreme Court a second time.

Issue.

Whether a federal court may award injunctive relief against state officials on the basis of state law.

Held.

JUSTICE POWELL holding:  No.  To allow federal courts to tell state officials how to apply state law would infringe on the sovereign immunity guaranteed to the States by the Eleventh Amendment.  Therefore, the lower courts could not enjoin the school officials.  On remand, however, the lower court can decide if an injunction would be warranted under the constitutional or federal claims.

Dissent.

Justice Brennan

Justice Brennan dissented, reasoning that the Eleventh Amendment prevents “federal court suits against States only by citizens of other States.”  Therefore, because Pennsylvania citizens were suing a Pennsylvania institution, the Eleventh Amendment should not have barred the claim.

Discussion.

The majority reasoned that the Eleventh Amendment was enacted to leave no doubt that States could not be sued without their consent.  In Ex parte Young, 209 U.S. 123 (1908), the Court crafted a narrow exception to this rule by enabling state officials to be sued when their actions could be deemed unconstitutional.  However, a party cannot simply name a state official instead of the State itself to overcome the Eleventh Amendment.  If the suit naming a state official is “in fact a suit against a State,” it will be barred by the Eleventh Amendment.  Further, while Ex parte Young allows plaintiffs to sue state officials for injunctive relief, plaintiffs may not sue state officials for damages (or “retroactive relief”).  See Edelman v. Jordan, 415 U.S. 651 (1974).  If a plaintiff wishes to bring “a suit against state officials for retroactive monetary relief, whether based on federal or state law, [it] must be brought in state court.”