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Pennhurst State School and Hospital v. Halderman

Supreme Court of the United States · Constitutional Law

Constitutional LawEleventh AmendmentSovereign ImmunityFederal CourtsEleventh Amendmentstate sovereign immunitystate officialsstate law claims

Facts

This litigation concerned conditions at Pennhurst State School and Hospital, a Pennsylvania institution for the care of the mentally retarded. Respondents sued Pennhurst, Pennsylvania state agencies and officials, and certain county officials, alleging violations of federal constitutional provisions, federal statutes, and Pennsylvania's MH/MR Act, and sought damages and injunctive relief. The District Court found seriously deficient and dangerous conditions and entered broad injunctive relief governing placement and care of residents. After a prior remand from this Court, the Court of Appeals upheld that relief solely on the basis of the state MH/MR Act.

Issue

May a federal court award prospective injunctive relief against state officials solely on the basis of state law? Does pendent jurisdiction permit a federal court to adjudicate such state-law claims notwithstanding the Eleventh Amendment?

Rule

The Eleventh Amendment bars a federal court from ordering state officials to conform their conduct to state law when the relief sought and ordered operates against the State. The Ex parte Young and Edelman exception for suits against state officials applies to violations of federal law, not state law, and pendent jurisdiction cannot override the Eleventh Amendment's constitutional limitation on federal judicial power.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Residents of a state-run veterans home in Columbus, Ohio sue the home's director and the head of the Ohio Department of Care Services in federal court. Their complaint alleges only that the officials are violating an Ohio statute requiring specific staffing ratios, and they seek an injunction ordering compliance going forward.

May the federal court grant the requested injunction?

Explanation. The majority held that a federal court may not enjoin state officials on the basis of state law when the relief operates against the State. Ex parte Young's allowance of prospective relief is limited to vindicating federal law, not state law. Because the requested order would direct state officials how to comply with Ohio law in operating a state institution, the Eleventh Amendment bars it. (Derived from Pennhurst State School and Hospital v. Halderman (n.d.).)