Edelman v. Jordan

1974

Venue: SCOTUS

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.

Posture: Suit in federal court for declarative and injunctive relief as well as retroactive benefits. District court grants the injunction. 7th cir affirms.

Issue: Can these remedies be granted?

Holding: Yes and no-- reversed on the retroactive benefits.

Rule: Suits by private parties that seek liability to be paid from public funds of the state are barred by 11A.

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.

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.