Pennhurst State Sch. & Hosp. v. Halderman - 465 U.S. 89, 104 S. Ct. 900 (1984)

Rule:

The Eleventh Amendment bars a suit against state officials when the state is the real, substantial party in interest. The general rule is that relief sought nominally against a state officer is in fact against the sovereign if the decree would operate against the latter. And, as when the state itself is named as the defendant, a suit against state officials that is in fact a suit against a state is barred regardless of whether it seeks damages or injunctive relief.

Facts:

Respondent Halderman, a resident of petitioner Pennhurst State School and Hospital, a Pennsylvania institution for the care of the mentally retarded, brought a class action in Federal District Court against Pennhurst, certain of its officials, the Pennsylvania Department of Public Welfare, and various state and county officials (also petitioners). It was alleged that conditions at Pennhurst violated various federal constitutional and statutory rights of the class members as well as their rights under the Pennsylvania Mental Health and Mental Retardation Act of 1966 (MH/MR Act). Ultimately, the District Court awarded injunctive relief based in part on the MH/MR Act, which was held to provide a right to adequate habilitation. The Court of Appeals affirmed, holding that the MH/MR Act required the State to adopt the "least restrictive environment" approach for the care of the mentally retarded, and rejecting petitioners' argument that the Eleventh Amendment barred a federal court from considering this pendent state-law claim. The court reasoned that since that Amendment did not bar a federal court from granting prospective injunctive relief against state officials on the basis of federal claims, citing Ex parte Young, 209 U.S. 123, the same result obtained with respect to a pendent state-law claim.

Issue:

 Did the Eleventh Amendment prohibit the District Court from ordering state officials to conform their conduct to state law?

Answer:

Yes

Conclusion:

The Supreme Court held that federal courts lacked jurisdiction under U.S. Const. amend. XI to enjoin petitioners' actions on the basis of a state law. The record showed that the officials acted in good faith; thus, any state law violation was caused by the state itself in not having fulfilled its legislative promises. Federal courts had no jurisdiction because the relief was sought was against the state. The Court held that federal courts did not have pendent jurisdiction over respondents' claims because pendent jurisdiction could not override the Eleventh Amendment. Federal courts had to examine each claim and determine if their jurisdiction was barred by the amendment. Policy considerations could not override the constitutional limitation on the federal judiciary to adjudicate suits against respondents. Federal courts also had no jurisdiction over the claims against a county because the relief sought ran to the state.