Atascadero State Hosp. v. Scanlon - 473 U.S. 234, 105 S. Ct. 3142 (1985)

Rule:

Congress must unequivocally express its intention to abrogate U.S. Const. amend. XI bar to suits against the States in federal court. Congress may abrogate the States' constitutionally secured immunity from suit in federal court only by making its intention unmistakably clear in the language of the statute. The fundamental nature of the interests implicated by the Eleventh Amendment dictates this conclusion.

Facts:

Respondent, who suffers from diabetes and has no sight in one eye, brought an action in Federal District Court against petitioners, alleging that petitioner California State Hospital denied him employment because of his physical handicap, in violation of § 504 of the Rehabilitation Act of 1973, and seeking compensatory, injunctive, and declaratory relief. Section 504 provides that no handicapped person shall, solely by reason of his handicap, be subjected to discrimination under any program receiving federal financial assistance under the Act. Section 505(a) makes available to any person aggrieved by any act of any recipient of federal assistance under the Act the remedies for employment discrimination set forth in Title VI of the Civil Rights Act of 1964. The District Court granted petitioners' motion to dismiss the complaint on the ground that respondent's claims were barred by the Eleventh Amendment. Ultimately, after initially affirming on other grounds and upon remand from the Supreme Court, the Court of Appeals reversed, holding that the Eleventh Amendment did not bar the action because the State by receiving funds under the Act had implicitly consented to be sued as a recipient under § 504. Petitioner sought review of the decision.

Issue:

Were the respondent’s claims barred by the Eleventh Amendment? 

Answer:

Yes.

Conclusion:

The Supreme Court held that Cal. Const. art. III, § 5, permitting suits against the state as directed by law, did not constitute a waiver of the state's constitutional immunity. In order for the state's constitutional provision to constitute a waiver of U.S. Const. XI immunity, the provision had to specify the state's intention to subject itself to suit in federal court. The Court held that Congress did not abrogate the state's U.S. Const. XI immunity in adopting the Act. General authorization for suit in federal court was not the kind of unequivocal statutory language sufficient to abrogate U.S. Const. amend. XI. The Court held that the Act did not manifest a clear intent to condition participating in funded programs on states' consent to waive their U.S. Const. XI immunity.