465 U.S. 89, 104 S.Ct. 900, 79 L.Ed.2d 67 (1984)
In 1974 Terri Lee Halderman, a resident of Pennhurst State School and Hospital, filed suit in the District Court for the Eastern District of Pennsylvania.1 The case became a class action on behalf of all present and future residents of the institution.2 The Pennsylvania Association for Retarded Citizens and the United States joined as plaintiffs.3 Defendants included Pennhurst and its officials, the Pennsylvania Department of Public Welfare and its officials, and county officials from five surrounding counties.4
The amended complaint alleged that conditions at Pennhurst violated rights under the Eighth and Fourteenth Amendments, section 504 of the Rehabilitation Act of 1973, the Developmentally Disabled Assistance and Bill of Rights Act, and the Pennsylvania Mental Health and Mental Retardation Act of 1966.5 Both damages and injunctive relief were sought.6
After a lengthy trial the District Court found in 1977 that conditions were dangerous, with residents often physically abused or drugged by staff, and inadequate for habilitation.7 Some residents suffered deterioration in physical, intellectual, and emotional skills.8 The court ordered immediate steps to remove residents from Pennhurst, directed the provision of community living arrangements, and appointed a Special Master with broad supervisory powers.9
The Court of Appeals affirmed most of the judgment in 1979 but remanded for individual determinations regarding institutionalization.10 On further remand the District Court established procedures for individual habilitation plans and appointed a Hearing Master.11 This Court in 1981 reversed the Court of Appeals' reliance on federal statutory grounds and remanded for consideration of state-law, constitutional, and section 504 claims.12 On remand the Court of Appeals in 1982 reinstated its prior judgment solely on the state Mental Health and Mental Retardation Act after the Pennsylvania Supreme Court decision in In re Schmidt.13 It rejected Eleventh Amendment and abstention challenges.14 The Supreme Court granted certiorari in 1982.15 The District Court had found that the individual defendants acted in good faith within the sphere of their official responsibilities despite staff shortages and limited resources.16
Whether a federal court may award injunctive relief against state officials on the basis of state law?17
The Eleventh Amendment constitutes a constitutional limitation on federal judicial power that bars suits against state officials for injunctive relief based on state law, because such suits are in reality against the State itself.18 The exception recognized in Ex parte Young applies only when the claim rests on a violation of federal law and thereby strips the official of state-law authority.
No. The District Court found that conditions at Pennhurst violated the Pennsylvania Mental Health and Mental Retardation Act.19 It ordered state officials to provide community living arrangements and appointed a Special Master to supervise compliance.20 The Court of Appeals affirmed that judgment solely on the basis of the state statute after this Court had rejected the federal statutory ground.21 The relief ordered requires ongoing state funding and institutional action that can be taken only by officials acting in their official capacities.22
The District Court expressly found that the individual defendants acted within the sphere of their official responsibilities.23
A federal court may not award injunctive relief against state officials on the basis of state law.24
Related opinions on this issue
Justice Brennan filed a separate dissent agreeing with Justice Stevens that the Eleventh Amendment does not bar the suit.25 He explained that because the conduct of the state officials was prohibited by state law, it could not be attributed to the sovereign and therefore the officials were not entitled to immunity.26 In addition, Justice Brennan maintained his long-held view that the Eleventh Amendment bars only suits brought by citizens of other states against a state.27
He would have held that Pennsylvania could not invoke the Amendment's protection in a suit brought by its own citizens.28
Joined by Justice Brennan, Justice Marshall, And Justice Blackmun
Justice Stevens argued that sovereign immunity never protects state officials whose conduct violates the positive commands of state law, because the sovereign cannot authorize unlawful acts.29 He reviewed an extensive line of precedent holding that officers acting contrary to state statutes are stripped of official character and may be enjoined.30 He charged that the majority had repudiated at least twenty-eight decisions spanning more than a century.31
Justice Stevens concluded that the Eleventh Amendment does not shield officials who violate the very statutes that define their authority.32
Whether the Eleventh Amendment prohibits a federal court from ordering state officials to conform their conduct to state law?33
The Eleventh Amendment deprives federal courts of jurisdiction over any claim that state officials violated state law in carrying out their official duties, whether the relief sought is prospective or retroactive, because the claim is against the State itself.
Yes. The District Court and Court of Appeals ordered state officials to operate Pennhurst in accordance with the least-restrictive-environment mandate of the Pennsylvania Mental Health and Mental Retardation Act.34 That mandate is a state-law duty.35 The resulting injunction requires the expenditure of state funds and the restructuring of a state institution.36 The relief therefore operates directly against the State and is barred regardless of the prospective character of the decree.37
The Eleventh Amendment prohibits a federal court from ordering state officials to conform their conduct to state law.38
Related opinions on this issue
Justice Brennan reiterated that the Eleventh Amendment does not apply to suits by a state's own citizens.39 He added that, even if it did, the Amendment would not shield officials whose conduct was forbidden by state law.40 Justice Brennan would have permitted the federal courts to enforce the state statute against the officials.41
Joined by Justice Brennan, Justice Marshall, And Justice Blackmun
Justice Stevens maintained that the Eleventh Amendment has never been understood to immunize officials who violate the very statutes that define their authority.42 He demonstrated that every prior decision of the Court had permitted injunctive relief when state officers acted contrary to state law.43 Justice Stevens concluded that the majority's new rule was inconsistent with more than a century of precedent.44
Whether the doctrine of pendent jurisdiction permits a federal court to adjudicate state-law claims against state officials?45
Pendent jurisdiction is a judge-made doctrine that cannot override the explicit constitutional limitation of the Eleventh Amendment; a federal court must examine each claim separately to determine whether the Eleventh Amendment bars its adjudication.
No. Although the federal constitutional and statutory claims provided a basis for federal jurisdiction, the Court of Appeals decided the case solely on the pendent state-law claim under the Mental Health and Mental Retardation Act.46 The Eleventh Amendment is an independent limitation on Article III power that applies to pendent claims with the same force as to federal claims.47 Therefore the state-law claim could not be adjudicated in federal court.48
The doctrine of pendent jurisdiction does not permit a federal court to adjudicate state-law claims against state officials when the Eleventh Amendment bars those claims.49
Related opinions on this issue
Joined by Justice Brennan, Justice Marshall, And Justice Blackmun
Justice Stevens argued that the majority's refusal to entertain the state-law claim forced federal courts to decide unnecessary federal constitutional questions.53 He observed that this result was contrary to the long-standing policy of avoiding constitutional adjudication when state-law grounds are available.54 Justice Stevens concluded that the majority's approach undermined judicial restraint.55
Whether the judgment may be upheld against county officials on the basis of state law?56
Even if county officials are not themselves immune, a judgment that requires the restructuring and funding of a state institution cannot be sustained solely against county officials when the underlying state statute contemplates cooperative action between state and county authorities and the relief necessarily runs against the State.
No. The District Court's order required the closing or substantial alteration of Pennhurst, a state institution operated by state officials.57 The funding for community placements and the Masters' fees came almost entirely from the State.58 The Mental Health and Mental Retardation Act envisions joint state-county responsibility.59 Any relief limited to county officials would therefore be partial and ineffective.60
The judgment may not be upheld against county officials on the basis of state law.61