Fitzpatrick v. Bitzer
Encyclopedia
Fitzpatrick v. Bitzer, 427 U.S. 445
(1976), was a United States Supreme Court
decision that determined that the U.S. Congress
has the power to abrogate
the Eleventh Amendment
sovereign immunity
of the states
, if this is done pursuant to its Fourteenth Amendment
power to enforce upon the states the guarantees of the Fourteenth Amendment.
based on race, color, religion, sex, national origin. The plaintiff
s, male retirees sued the state of Connecticut
for sex discrimination against them in its retirement policies. Connecticut invoked its Eleventh Amendment sovereign immunity, and the District Court, and Court of Appeals both allowed only injunctive
relief, denying monetary recovery (although the Court of Appeals permitted attorney's fees). Both of those courts pointed to Edelman v. Jordan
, 415 U.S. 651
(1974), a prior United States Supreme Court case which had held that the Eleventh Amendment prohibits a federal court
from ordering a U.S. state to pay money to an individual wronged by the state. The plaintiffs appealed to the Supreme Court.
William Rehnquist
, distinguished previous cases where individuals had attempted to sue the states for money damages (or the equivalent) — including Edelman v. Jordan — because those cases had not involved an express provision by Congress permitting such a lawsuit. The Court ruled that Congress has the power under the Fourteenth Amendment to abrogate sovereign immunity of states, because the Fourteenth Amendment was enacted specifically to limit the power of the states, with the purpose of enforcing civil rights guarantees against them.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1976), was a United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
decision that determined that the U.S. Congress
United States Congress
The United States Congress is the bicameral legislature of the federal government of the United States, consisting of the Senate and the House of Representatives. The Congress meets in the United States Capitol in Washington, D.C....
has the power to abrogate
Abrogation doctrine
The Abrogation doctrine is a constitutional law doctrine expounding when and how the Congress may waive a state's sovereign immunity and subject it to lawsuits to which the state has not consented ....
the Eleventh Amendment
Eleventh Amendment to the United States Constitution
The Eleventh Amendment to the United States Constitution, which was passed by the Congress on March 4, 1794, and was ratified on February 7, 1795, deals with each state's sovereign immunity. This amendment was adopted in order to overrule the U.S. Supreme Court's decision in Chisholm v...
sovereign immunity
Sovereign immunity
Sovereign immunity, or crown immunity, is a legal doctrine by which the sovereign or state cannot commit a legal wrong and is immune from civil suit or criminal prosecution....
of the states
U.S. state
A U.S. state is any one of the 50 federated states of the United States of America that share sovereignty with the federal government. Because of this shared sovereignty, an American is a citizen both of the federal entity and of his or her state of domicile. Four states use the official title of...
, if this is done pursuant to its Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
power to enforce upon the states the guarantees of the Fourteenth Amendment.
Facts
In 1972, Congress amended Title VII of the Civil Rights Act of 1964 (42 U.S.C. § 2000e, Chapter 21, Subchapter VI) to allow individuals to sue state governments for money damages for discriminationDiscrimination
Discrimination is the prejudicial treatment of an individual based on their membership in a certain group or category. It involves the actual behaviors towards groups such as excluding or restricting members of one group from opportunities that are available to another group. The term began to be...
based on race, color, religion, sex, national origin. The plaintiff
Plaintiff
A plaintiff , also known as a claimant or complainant, is the term used in some jurisdictions for the party who initiates a lawsuit before a court...
s, male retirees sued the state of Connecticut
Connecticut
Connecticut is a state in the New England region of the northeastern United States. It is bordered by Rhode Island to the east, Massachusetts to the north, and the state of New York to the west and the south .Connecticut is named for the Connecticut River, the major U.S. river that approximately...
for sex discrimination against them in its retirement policies. Connecticut invoked its Eleventh Amendment sovereign immunity, and the District Court, and Court of Appeals both allowed only injunctive
Injunction
An injunction is an equitable remedy in the form of a court order that requires a party to do or refrain from doing certain acts. A party that fails to comply with an injunction faces criminal or civil penalties and may have to pay damages or accept sanctions...
relief, denying monetary recovery (although the Court of Appeals permitted attorney's fees). Both of those courts pointed to Edelman v. Jordan
Edelman v. Jordan
Edelman v. Jordan, 415 U.S. 651 , was a United States Supreme Court case that held that, because of the sovereign immunity recognized in the Eleventh Amendment, a federal court could not order a State to pay back funds unconstitutionally withheld from parties to whom they were due.-Facts:The...
, 415 U.S. 651
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1974), a prior United States Supreme Court case which had held that the Eleventh Amendment prohibits a federal court
United States federal courts
The United States federal courts make up the judiciary branch of federal government of the United States organized under the United States Constitution and laws of the federal government.-Categories:...
from ordering a U.S. state to pay money to an individual wronged by the state. The plaintiffs appealed to the Supreme Court.
Issue
Can Congress abrogate state sovereign immunity under Section 5 of the Fourteenth Amendment?Result
The Court, in an opinion by JusticeAssociate Justice of the Supreme Court of the United States
Associate Justices of the Supreme Court of the United States are the members of the Supreme Court of the United States other than the Chief Justice of the United States...
William Rehnquist
William Rehnquist
William Hubbs Rehnquist was an American lawyer, jurist, and political figure who served as an Associate Justice on the Supreme Court of the United States and later as the 16th Chief Justice of the United States...
, distinguished previous cases where individuals had attempted to sue the states for money damages (or the equivalent) — including Edelman v. Jordan — because those cases had not involved an express provision by Congress permitting such a lawsuit. The Court ruled that Congress has the power under the Fourteenth Amendment to abrogate sovereign immunity of states, because the Fourteenth Amendment was enacted specifically to limit the power of the states, with the purpose of enforcing civil rights guarantees against them.