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Fitzpatrick v. Bitzer

Supreme Court of United States
427 U.S. 445 (1976)
ELI5:

Rule of Law:

Congress has the authority to abrogate a state's Eleventh Amendment sovereign immunity when it legislates pursuant to its enforcement power under Section 5 of the Fourteenth Amendment.


Facts:

  • The State of Connecticut maintained a statutory retirement benefit plan for its employees.
  • Certain provisions of the retirement plan discriminated against male employees on the basis of their sex.
  • In 1972, Congress amended Title VII of the Civil Rights Act of 1964, extending its prohibitions against employment discrimination to state and local governments.
  • Male employees of the State of Connecticut, represented by Fitzpatrick, asserted that the state's retirement plan violated the amended Title VII.
  • As a result of the plan's discriminatory provisions, the male employees suffered financial losses in the form of reduced retirement benefits.

Procedural Posture:

  • Present and retired male employees of Connecticut (Petitioners) sued state officials (Respondents), including Bitzer, in the U.S. District Court for the District of Connecticut.
  • The District Court, a trial court, found that the state's retirement plan violated Title VII and granted prospective injunctive relief.
  • The District Court denied the employees' request for retroactive retirement benefits and attorneys' fees, holding such monetary awards were barred by the Eleventh Amendment.
  • The employees, as appellants, appealed to the U.S. Court of Appeals for the Second Circuit, an intermediate appellate court.
  • The Court of Appeals affirmed the denial of retroactive benefits but reversed the denial of attorneys' fees, finding the latter to have only an 'ancillary effect' on the state treasury.
  • The employees (as petitioners in No. 75-251) and the state officials (as cross-petitioners in No. 75-283) successfully petitioned the U.S. Supreme Court for a writ of certiorari.

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Issue:

Does Congress, pursuant to its enforcement power under Section 5 of the Fourteenth Amendment, have the authority to abrogate a state's Eleventh Amendment sovereign immunity and authorize federal courts to award retroactive money damages against the state?


Opinions:

Majority - Justice Rehnquist

Yes. When Congress acts pursuant to Section 5 of the Fourteenth Amendment, it has the power to authorize federal courts to enter monetary awards against a state, thereby abrogating the state's Eleventh Amendment immunity. The Fourteenth Amendment, by its very nature, was intended to be a limitation on the power of the States and an enlargement of the power of Congress. Section 5 expressly grants Congress the power to enforce the substantive provisions of the Amendment, which are directed at the states, through 'appropriate legislation.' This power fundamentally altered the federal-state balance and allows Congress to provide for private suits against states that would be constitutionally impermissible in other contexts. In this case, the 1972 amendments to Title VII were a clear exercise of Congress's Section 5 power, and they explicitly authorized suits for damages against state employers.


Concurring - Justice Brennan

Yes. The Eleventh Amendment does not bar this suit because states surrendered their sovereign immunity 'in the plan of the Convention' when they granted Congress enumerated powers, such as the power to regulate commerce and enforce the Fourteenth Amendment. Because of this surrender of immunity at the Constitution's founding, no immunity exists that can be the subject of a congressional abrogation or a voluntary waiver when Congress acts within these granted powers. Therefore, Connecticut may not assert sovereign immunity as a defense to a claim for damages under Title VII.


Concurring - Justice Stevens

Yes. The Eleventh Amendment defense should be rejected, but on grounds different from the majority's. This action is permissible under the doctrine of Ex parte Young, which allows suits against state officers to enjoin the enforcement of an unconstitutional statute. Furthermore, the award here is distinguishable from that in Edelman v. Jordan because it would be paid from independent pension funds, not directly from the state treasury. The fact that the state would later have to reimburse those funds is an ancillary financial consequence, similar to the costs of complying with prospective relief, and does not trigger the Eleventh Amendment bar.



Analysis:

This decision established a crucial exception to the principle of state sovereign immunity under the Eleventh Amendment, significantly empowering Congress to enforce civil rights against the states. It clarified that the Fourteenth Amendment fundamentally altered the balance of power between the federal government and the states. By holding that Section 5 is a valid font of congressional power to abrogate state immunity, the Court created a pathway for individuals to seek monetary remedies directly from state treasuries for violations of federal anti-discrimination laws. This precedent underpins the enforceability of numerous civil rights statutes against state governments.

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