Puerto Rico Aqueduct & Sewer Authority v. Metcalf & Eddy, Inc.
Supreme Court of the United States · 1993 · Civil Procedure
Civil ProcedureAppellate JurisdictionCollateral Order DoctrineEleventh Amendment Immunity28 U.S.C. § 1291final decisionscollateral order doctrineCohen
Facts
PRASA is an autonomous government instrumentality of Puerto Rico that provides water and sewage services. After entering a consent decree with the EPA, PRASA contracted with Metcalf & Eddy, a private Delaware engineering firm, to help upgrade wastewater treatment plants. PRASA later withheld payments, alleging overcharging, and Metcalf & Eddy sued in federal district court for breach of contract and damage to business reputation. PRASA moved to dismiss, claiming it was an arm of the State entitled to Eleventh Amendment immunity, but the district court denied the motion.
Issue
May a State or a state entity claiming to be an arm of the State immediately appeal a district court order denying its claim of Eleventh Amendment immunity under the collateral order doctrine?
Rule
A district court order denying a claim by a State or an entity claiming to be an arm of the State to Eleventh Amendment immunity is immediately appealable under the collateral order doctrine because such an order conclusively rejects a claimed immunity from suit, resolves an important issue separate from the merits, and would be effectively unreviewable after final judgment.
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10 practice questions + 4 AI-graded essays on this case
One of 10 multiple-choice questions for this case. Pick an answer to see why.
Lakeshore Transit Board, a public transportation authority created by Illinois law, is sued in federal district court in Chicago for damages on a state-law contract claim. The authority moves to dismiss, arguing that it is an arm of the State and therefore immune from suit in federal court under the Eleventh Amendment, but the district court denies the motion.
May the authority immediately appeal the denial under 28 U.S.C. § 1291?
Explanation. A district court order denying a claim by a State or an entity claiming to be an arm of the State to Eleventh Amendment immunity is immediately appealable under the collateral order doctrine. The majority treated Eleventh Amendment immunity as an immunity from suit in federal court, not merely a defense to liability, so the order conclusively rejects a claimed right not to be sued, resolves an important issue separate from the merits, and would be effectively unreviewable after final judgment.