Papasan v. Allain
478 U.S. 265 (1986)
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Rule of Law:
The Eleventh Amendment does not bar a claim against state officials for an ongoing violation of the Equal Protection Clause, such as the current unequal distribution of the benefits of state-held assets. A state's unequal distribution of its own resources among school districts is subject to rational basis review and is not automatically validated by precedents that permit funding disparities based on local property taxes.
Facts:
- In the 19th century, the United States Congress granted lands to the State of Mississippi, with Section 16 of each township reserved for the support of local schools.
- The northern 23 counties of Mississippi, known as the Chickasaw Cession, were ceded to the U.S. by the Chickasaw Nation in 1832, and no Section 16 lands were reserved from sale.
- In 1836, Congress granted Mississippi "lieu lands" to compensate the Chickasaw Cession, with title vested in the State "for the use of schools within [the Chickasaw Cession]."
- In 1856, with congressional authorization, the Mississippi legislature sold the lieu lands and invested the proceeds of over $1 million in loans to state railroad companies.
- The state's railroad investments were destroyed during the Civil War, and the principal from the sale of the lieu lands was permanently lost.
- Since the late 19th century, the Mississippi legislature has made small annual appropriations to the Chickasaw Cession schools as "interest" on the lost principal.
- This system resulted in a significant funding disparity; in 1984, Chickasaw Cession schools received an estimated $0.63 per pupil from this funding source, compared to an average of $75.34 per pupil for schools in the rest of the state that benefited from existing Section 16 lands.
Procedural Posture:
- Local school officials and schoolchildren from the Chickasaw Cession (Petitioners) sued Mississippi state officials (Respondents) in the United States District Court for the Northern District of Mississippi.
- The complaint alleged, among other things, a breach of trust regarding federal land grants and a violation of the Equal Protection Clause of the Fourteenth Amendment.
- The District Court dismissed the complaint, holding that the claims were barred by the Eleventh Amendment and the applicable statute of limitations.
- Petitioners appealed to the U.S. Court of Appeals for the Fifth Circuit.
- The Court of Appeals affirmed the dismissal, agreeing that the trust claim was barred by the Eleventh Amendment and holding that the equal protection claim, while not barred, failed to state a claim upon which relief could be granted under San Antonio Independent School Dist. v. Rodriguez.
- The Supreme Court of the United States granted certiorari to review the judgment of the Court of Appeals.
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Issue:
Does an alleged ongoing disparity in state funding for public schools, resulting from the state's historical mismanagement and current unequal distribution of benefits from federal land grants, state a valid claim under the Equal Protection Clause that is not barred by the Eleventh Amendment?
Opinions:
Majority - Justice White
Yes. An alleged ongoing violation of the Equal Protection Clause is not barred by the Eleventh Amendment, and a claim that a state unequally distributes state-held assets among its school districts is not foreclosed by precedent concerning disparities from local funding. The petitioners' trust claim is barred by the Eleventh Amendment because it seeks compensation for a past breach of trust, which is tantamount to a retroactive award of damages barred by Edelman v. Jordan. However, the equal protection claim is not barred because it alleges an ongoing constitutional violation—the present unequal distribution of benefits from state-held school lands. This claim for prospective relief falls under the Ex parte Young exception. Furthermore, the Court of Appeals erred in dismissing the claim under San Antonio Independent School Dist. v. Rodriguez. Rodriguez approved disparities resulting from local property taxation as rationally related to the legitimate state interest in local control. This case is different because the disparity stems not from local decisions, but from the State's own decision to distribute the benefits of state-held assets unequally. The case must be remanded to determine whether this unequal distribution is rationally related to a legitimate state purpose.
Concurring-in-part-and-dissenting-in-part - Justice Brennan
Agrees with the judgment on the equal protection claim but dissents from the Eleventh Amendment analysis. Justice Brennan reiterates his view that the Court’s Eleventh Amendment jurisprudence, beginning with Hans v. Louisiana, is historically and logically flawed and should be overturned. He argues that the Framers never intended the Eleventh Amendment to bar citizens from suing their own state for violations of federal law.
Concurring-in-part-and-dissenting-in-part - Justice Blackmun
Agrees with the judgment on the equal protection claim but dissents from the dismissal of the trust claims. Justice Blackmun argues that by accepting the federal land grants and the conditions attached, Mississippi waived its Eleventh Amendment immunity. He contends that the petitioners have stated a valid claim for breach of trust that should survive a motion to dismiss and potentially entitle them to damages.
Concurring-in-part-and-dissenting-in-part - Justice Powell
Agrees that the trust claims are barred by the Eleventh Amendment but dissents from the Court's holding on the equal protection claim. Justice Powell argues that the equal protection claim should have been dismissed because the public record shows the disputed funds are an insignificant part (less than 1.5%) of overall school funding in Mississippi. He contends that when viewing total per-pupil expenditures, there is no significant detriment to the Chickasaw Cession schools, and therefore, the disparity in this one minor funding stream cannot rise to the level of a constitutional violation.
Analysis:
This case significantly refines the scope of equal protection challenges to state school funding systems. By distinguishing San Antonio v. Rodriguez, the Court clarified that while disparities arising from local taxation are often permissible, a state's own unequal distribution of state-controlled resources is subject to a distinct rational basis inquiry. This decision opened a new avenue for litigation focusing on specific discriminatory components of state funding formulas, rather than requiring a challenge to the entire system. It also reinforced the distinction under the Eleventh Amendment between claims for past monetary damages (barred) and claims seeking to end ongoing constitutional violations (permitted under Ex parte Young).
