| Edelman v. Jordan | ||||||||||||
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| Argued December 12, 1973 Decided March 25, 1974 |
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| Holding | ||||||||||||
| The Court 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. Sovereign immunity, or crown immunity, is a type of immunity that in Common law Jurisdictions traces its origins from early English law The Eleventh Amendment ( Amendment XI) of the United States Constitution was passed by the U The United States federal courts are the system of Courts organized under the Constitution and laws of the Federal government of the United States A US state is any one of the fifty subnational entities of the United States of America that share Sovereignty with the federal government | ||||||||||||
| Court membership | ||||||||||||
| Chief Justice: Warren E. Burger Associate Justices: William O. Douglas, William J. Brennan, Jr., Potter Stewart, Byron White, Thurgood Marshall, Harry Blackmun, Lewis F. Powell, Jr., William Rehnquist |
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| Case opinions | ||||||||||||
| Majority by: Rehnquist Joined by: Burger, Stewart, White, Powell Dissent by: Douglas Dissent by: Brennan Dissent by: Marshall Joined by: Blackmun |
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| Laws applied | ||||||||||||
| U.S. Const. amend. XI | ||||||||||||
Edelman v. Warren Earl Burger ( September 17 1907 – June 25 1995) was Chief Justice of the United States from 1969 to 1986 William Orville Douglas ( October 16, 1898 – January 19, 1980) was a United States Supreme Court Associate Justice. William Joseph Brennan Jr ( April 25, 1906 &ndash July 24, 1997) was an Associate Justice of the Supreme Court of the Potter Stewart ( January 23 1915 &ndash December 7 1985) was an Associate Justice of the United States Supreme Court. Byron Raymond White ( June 8, 1917 &ndash April 15, 2002) won fame both as a football Running back and as an associate justice of Thurgood Marshall ( July 2, 1908 – January 24, 1993) was an American Jurist and the first African American Harry Andrew Blackmun ( November 12, 1908 &ndash March 4, 1999) was an Associate Justice of the Supreme Court of the United States Lewis Franklin Powell Jr ( September 19, 1907 &ndash August 25, 1998) was an Associate Justice of the Supreme Court of the William Hubbs Rehnquist (October 1 1924 – September 3 2005 was an American lawyer, jurist, and a political figure who served as an Associate Justice The Eleventh Amendment ( Amendment XI) of the United States Constitution was passed by the U Jordan, 415 U.S. 651 (1974), 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. 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 Year 1974 ( MCMLXXIV) was a Common year starting on Tuesday (link will display full calendar of the 1974 Gregorian calendar. The Supreme Court of the United States is the highest judicial body in the United States and leads the federal judiciary. Sovereign immunity, or crown immunity, is a type of immunity that in Common law Jurisdictions traces its origins from early English law The Eleventh Amendment ( Amendment XI) of the United States Constitution was passed by the U The United States federal courts are the system of Courts organized under the Constitution and laws of the Federal government of the United States A US state is any one of the fifty subnational entities of the United States of America that share Sovereignty with the federal government
Contents |
Facts
The Plaintiff, John Jordan, had sued a department of the state of Illinois, alleging that a federal-state program of Aid to the Aged, Blind, or Disabled (AABD) had been administered in a way that violated both federal laws and the Fourteenth Amendment to the U.S. Constitution. A plaintiff ( Π in Legal shorthand) also known as a claimant or complainant, is the party who initiates a Lawsuit The State of Illinois ( roughly ill-i-NOY is a state of the United States of America, the 21st to be admitted to the Union. The Fourteenth Amendment ( Amendment XIV) to the United States Constitution is one of the post- Civil War Reconstruction Amendments, first Specifically, Jordan claimed that the Illinois administrators were applying their own guidelines which ignored federally mandated time limits, thereby not getting aid to applicants fast enough. The federal law required that applicants who qualify receive aid within 30 or 45 days, depending on their condition, but the Illinois agency was taking up to four months to disburse aid - and when such aid was distributed, it was not paid retroactively to the time when the state should have started paying it according to the federal guidelines.
Jordan sought relief including a positive injunction to require the State to award him and others in his position the aid that they had missed because of the lateness in processing the applications. The United States District Court found the Illinois guidelines to be inconsistent with the federal statute, and ordered Illinois to follow the federal guidelines, and to release to the aid applicants all funds "wrongfully withheld". The United States district courts are the general Trial courts of the United States federal court system. The United States Court of Appeals for the Seventh Circuit affirmed, and the case was taken to the Supreme Court, with agency director Joel Edelmen named as the party representing the state of Illinois. The United States Court of Appeals for the Seventh Circuit is a federal court with Appellate jurisdiction over the courts in the following districts
Issue
Since the 1890 decision in Hans v. Louisiana, the Eleventh Amendment had been held to recognize the sovereign immunity of states from suits by their citizens. Year 1890 ( MDCCCXC) was a Common year starting on Wednesday (link will display the full calendar of the Gregorian calendar (or a Common Hans v Louisiana, 134 US 1 (1890 was a decision of the United States Supreme Court determining that the Eleventh Amendment prohibits the However, the 1908 case of Ex parte Young had allowed an exception, that citizens could seek injunctive relief against state officials to stop them from carrying out unconstitutional state policies. Year 1908 ( MCMVIII) was a Leap year starting on Wednesday (link will display the full calendar of the Gregorian calendar (or a Leap year Ex parte Young, 209 US 123 (1908 was a United States Supreme Court case that allowed suits in federal courts against officials acting on behalf of states
In this case, the Supreme Court would have to examine whether a federal court can require a state to restore money wrongfully withheld from citizens by the state, if the order to restore the funds is in the form of an injunction requiring the state to stop its wrongful possession of those funds. The United States federal courts are the system of Courts organized under the Constitution and laws of the Federal government of the United States
Result
The Court, in an opinion by then-Justice Rehnquist concluded that private litigants could not avoid the bar of state sovereign immunity by manipulating the doctrine of Ex parte Young. William Hubbs Rehnquist (October 1 1924 – September 3 2005 was an American lawyer, jurist, and a political figure who served as an Associate Justice Ex parte Young, 209 US 123 (1908 was a United States Supreme Court case that allowed suits in federal courts against officials acting on behalf of states No case examining state sovereign immunity had held that states could be required to repay funds that had wrongfully been withheld. In almost all those cases that had permitted retrospective recovery against the States, the State had not raised the issue of state sovereign immunity; the Court additionally overruled any cases in which the State had raised the issue and lost.
The Court distinguished the payment that had been ordered in this case from expenses that a State might incidentally incur after an injunction is issued in order to comply; the costs of post-judgment compliance are ancillary, whereas the costs of making up for pre-judgment non-compliance were more like an award of damages to the plaintiff. Noting that there were no precedents squarely on point, the Court expressed disapproval of those precedents that hinted at allowing restoration of funds previously withheld.
The Court also brushed aside an alternative theory raised by the Court of Appeals, that Illinois had waived it's immunity by participating in this federal program. Previous cases finding such a waiver had involved express language in the Congressional statute conditioning program funds on such a waiver - but in this statute, there was no such language. The Court refused to find that participation in the program constituted "constructive consent", instead declaring that consent to waive immunity from suit would only be found "by the most express language or by such overwhelming implications from the text as will leave no room for any other reasonable construction. "
The majority also rejected Justice Marshall's suggestion that plaintiffs could recover under the civil rights statute, 42 U.S.C. § 1983, noting that nothing in that statute suggested that Congress had intended to abrogate state sovereign immunity through its passage. Thurgood Marshall ( July 2, 1908 – January 24, 1993) was an American Jurist and the first African American The Civil Rights Act of 1871, also known as the Ku Klux Klan Act of 1871, is an important federal statute in force in the United States. Finally, the Court found that it was not improper to consider the state sovereign immunity issue even though the state had not raised it in the trial court, because the state sovereign immunity is a jurisdictional bar, which may be raised at any time. In Law, jurisdiction (from the Latin ius iuris meaning "law" and dicere meaning "to speak" is the practical Authority
Dissents
Justice Douglas, Justice Brennan, and Justice Marshall each dissented from the opinion of the Court. William Orville Douglas ( October 16, 1898 – January 19, 1980) was a United States Supreme Court Associate Justice. William Joseph Brennan Jr ( April 25, 1906 &ndash July 24, 1997) was an Associate Justice of the Supreme Court of the Thurgood Marshall ( July 2, 1908 – January 24, 1993) was an American Jurist and the first African American
Dissent of Justice Douglas
Justice Douglas asserted that there should be no distinction made between prospective relief and retrospective relief, as the drain on the state's treasury is the same in either case. He also strongly contended that Illinois had waived its immunity by entering the federal program, because the Court had recently found other states to have waived immunity by joining similar programs. Therefore, Douglas reasoned that Illinois had to have been aware of the possibility that entering the program would waive its own immunity, and its decision to participate in light of that danger showed a willingness to be held liable.
Dissent of Justice Marshall
Justice Marshall argued that 42 U.S.C. § 1983, which permits parties to sue state actors to recover for civil rights violations, also abrogated the immunity of the states, permitting a recovery from the state treasury where the rights of a citizen have been violated by an official of the state. The Civil Rights Act of 1871, also known as the Ku Klux Klan Act of 1871, is an important federal statute in force in the United States. A state actor is a term used in United States Civil rights Law to describe a person who is acting on behalf of a governmental body and is therefore subject
Dissent of Justice Brennan
Justice Brennan's opinion did not reach any of the questions on the limitations of sovereign immunity, or waiver thereof, that were considered by both the Court and the other dissents. Instead, Brennan argued that the Eleventh Amendment does not immunize states from being sued by their citizens at all. His position is that there is no question of what the purported immunity covers, or whether it can be waived, because there is no immunity. He notes that the Eleventh Amendment, by its language, only bars suits against a state by citizens of other states. This leaves common law sovereign immunity, which Brennan asserts was surrendered by the states at the time they agreed to join into the United States. Common law refers to law and the corresponding legal system developed through decisions of courts and similar tribunals rather than through legislative statutes or executive
See also
External links
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