Pennhurst State School & Hospital v. Halderman

In accordance with the Eleventh Amendment, if a legal claim is brought against a state official for violating a state law, then the federal court has no jurisdiction to grant relief unless the state actions are also violative of federal law.

Terri Lee Halderman was a resident of Pennhurst State School and Hospital, which is a state institution in Pennsylvania that was established for the care of the mentally retarded. In 1974, Halderman brought a class action suit on behalf of the present and any future residents of Pennhurst against the hospital, its officials, and other state and county officers, including the Pennsylvania Department of Public Welfare. The suit alleged that the hospital violated the plaintiffs' rights under the Eighth and Fourteenth Amendments, the Developmentally Disabled Assistance and Bill of Rights Act, as well as the Pennsylvania Mental Health and Retardation Act of 1966 (MH/MR).

In 1977, the district court ruled in favor of the plaintiffs, stating:

Conditions at Pennhurst are not only dangerous, with the residents often physically abused or drugged by staff members, but also inadequate for the habilitation of the retarded. Indeed, the court found that the physical, intellectual, and emotional skills of some residents have deteriorated at Pennhurst.

The district court held that the conditions at Pennhurst violated: (1) the Due Process Clause and the MH/MR Act, both of which provide for "minimally adequate habilitation," (2) The Eight Amendment's "freedom from harm" provision, applied to the states through the Fourteenth Amendment, and (3) the Equal Protection Clause and the Rehabilitation Act, both forbidding "discriminatory habilitation." Additionally, the district court held that "due process [requires] that if a state undertakes the habilitation of a retarded person, it must do so in the least restrictive setting [for] that individual's needs." The court ordered the retarded residents be removed and Pennhurst provide other living arrangements for the patients. A special master was appointed to oversee and implement these changes. The court ordered the hospital to be closed.

Pennhurst appealed this decision to the court of appeals. They based their appeal on the Eleventh Amendment of the U.S. Constitution, arguing that the amendment stated that the federal court did not have jurisdiction to rule on a state claim. The Federal Court of Appeals held that the Eleventh Amendment did not bar it from granting this type of injunctive relief against state officials because the same result would have been obtained with respect to the state-law claim. Thus, the court argued that it had pendant jurisdiction over the state portion. (Pendant jurisdiction exists when state and federal claims derive from a common nucleus of operative fact and the disposition of the nonfederal claims is deemed necessary to rule on the federal claim. In such cases, jurisdiction is said to extend to the entire claim, not just the federal parts.) Although the appellate court affirmed the lower court's decision and adopted the least restrictive means standard, it did not rely on the constitutional grounds, and only on the MH/MR Act. The court of appeals did not order the hospital to close, however, but rather stated that it was within the discretion of the district court and/or its court-appointed special master to determine on a case-by-case basis, which patients should be removed.

The Supreme Court noted three arguments presented to them by the hospital: (1) the Eleventh Amendment forbids federal courts from ordering state officials to conform their conduct to state law, (2) comity (the recognition of one court by another) prohibits the district court from issuing the injunction, and (3) the district court erred when it appointed the special master and others to supervise decisions on state law issues. In a 5-4 decision, the Supreme Court reversed the lower courts holding as to the first issue, and thus, never needed to address the final two claims.

The Eleventh Amendment bars suits against state officials where the state is a party, regardless of whether the injunctive relief is sought. However, in Ex parte Young (1908), the Court derived an exception to this rule. They determined that a suit challenging the actions of a state official, on federal constitutional claims, is not an action against the state, and thus, not violative of the Eleventh Amendment. This was an attempt at balancing the notion that federal law is supreme to state while still giving the states the sovereign immunity that is granted them in the Constitution.

The majority reasoned that Young does not and cannot apply to this case. Here, the lower federal courts were granting injunctive relief ordering state officials to act in conformity with state law. The Court found this to be the determining factor in the case. Young held that a state official's actions cannot violate federal law, but here the lower courts were stating that a state officials actions could not violate their own state's law. Here, the issue before the federal court was wholly a state issue.

Lawyers, judges, and other persons involved in the application of the law agree that this decision established an interesting precedent. Before this case, federal courts were inclined to avoid the constitutional issues if relief could be granted on non-constitutional grounds. However, in light of this holding, state law violation could no longer serve as the basis for an injunction, so the Court would have no choice but to rule on the federal constitutional claims. Before this case, if a court found a violation of state law, the state officials could change its laws if they were unhappy with the federal court's conclusion. However, after this case, if the court now determines that the state law violates the federal constitution, the state cannot undo or otherwise undermine the ruling. In any event, this case placed a much tighter restraint on the powers of the federal courts over the states.