Venue: |
SCOTUS
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Facts: |
Looks like the directors of public aid haven't been paying out benefits
to the aged, blind, and disabled in accordance with the law. |
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Posture: |
Suit in federal court for declarative and injunctive relief as well as
retroactive benefits. District
court grants the injunction. 7th cir affirms. |
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Issue: |
Can these remedies be granted? |
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Holding: |
Yes and no-- reversed on the retroactive benefits. |
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Rule: |
Suits by private parties that seek liability to be paid from public funds
of the state are barred by 11A. |
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Reasoning: |
Ex Parte Young was a landmard case, because it allowed the
Civil War Amendments to serve as a sword and not just a shield,
but the relief granted there was prospective only. Retroactive
benefits payments are different, and we should take that into
account. It makes sense that the state can be compelled to comply
with the law in the future, but monetary awards against the state
are barred. Why? Because even though the state officer is the
one who is being nominally sued for the unconstitutional act, it's
the state that will pay the damages. |
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Dicta: |
Brennan (dissenting): IL should not be able to assert sovereign immunity
here-- compliance with federal law was the sort of thing surrendered
in the plan of the convention. |
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