Supreme Court rules federal court may hear state agency claim against state officials

[JURIST] The US Supreme Court [official website] ruled [opinion, PDF] 6-2 Tuesday in Virginia Officer for Protection and Advocacy v. Stewart [Cornell LII backgrounder] that a state agency can sue state officials in federal court to remedy a violation of federal law. The Virginia Office for Protection and Advocacy (VOPA) is an independent state agency that is a designated "protection and advocacy" (P&A) system to protect and advocate for the rights of individuals with developmental disabilities under federal law. VOPA sought to force the disclosure of medical records from state officials relevant to the deaths of two individuals who were residents of state-run facilities. In an opinion by Justice Antonin Scalia, the court held that VOPA's action against state officials could proceed under the Ex parte Young [opinion text] doctrine. The court reasoned that the suit satisfies the inquiry under Ex Parte Young of whether the complaint alleges an ongoing violation of federal law, seeks the proper relief and does not offend the distinctive interests protected by sovereign immunity. The opinion stressed that the proper inquiry for determining when a suit is in fact against the sovereign is the effect of the relief sought and not who is bringing the action. The court rejected the respondents' claim that a state's dignity is diminished when a federal court adjudicates a dispute between its components, reasoning that VOPA's power to sue the state officials is a consequence of the Virginia's voluntary decision to establish a public P&A. Additionally, the court reasoned that a state's stature is not diminished to any greater degree when its own agency sues to enforce its officers' compliance with federal law as opposed to a private person bringing a same type of action:

Not every offense to a State's dignity constitutes a denial of sovereign immunity. The specific indignity against which sovereign immunity protects is the insult to a State of being haled into court without its consent; that does not occur just because a suit happens to be brought by another state agency.
The opinion recognized the novelty of VOPA's action, but emphasized that the action contained the necessary elements to invoke the Ex Parte Young exception. The dissent by Chief Justice John Roberts criticized the opinion of the court for expanding a narrow exception. The dissent argued that the majority's decision runs contrary to Alden v. Maine [opinion text] where the court objected to the federal government forcing a state to defend itself before itself.

The opinion overturns the ruling [opinion, PDF] by the US Court of Appeals for the Fourth Circuit [official website] that the suit by the petitioner was barred under the Eleventh Amendment and did not fall within the Ex Parte Young doctrine. The Fourth Circuit reasoned that a suit by a state agency against state officials is an intramural state dispute and to allow it to be brought in federal court would be inconsistent with our system of dual sovereignty. The Supreme Court heard arguments in the case [oral arguments transcript, PDF] last year.

 

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