Quern v. Jordan
440 U.S. 332, 59 L. Ed. 2d 358, 1979 U.S. LEXIS 67 (1979)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A federal court order requiring state officials to send a notice to class members, informing them of available state administrative procedures to determine eligibility for past benefits, does not violate the Eleventh Amendment as long as the relief is ancillary to prospective relief and does not constitute a direct monetary award from the state treasury.
Facts:
- John Jordan and a class of other applicants for the Aid to the Aged, Blind, and Disabled (AABD) program in Illinois experienced long delays in the processing of their applications by state officials.
- Due to these processing delays, Jordan and the other class members were wrongfully denied welfare benefits to which they were entitled for a period of time.
- The AABD program was a cooperative federal-state initiative administered at the state level by Illinois officials.
- Illinois maintained its own state administrative procedures through which individuals could appeal the denial of benefits and seek a determination on their eligibility for past, unpaid benefits.
Procedural Posture:
- John Jordan filed a class-action lawsuit against Illinois officials in the U.S. District Court for the Northern District of Illinois.
- The District Court granted summary judgment for the plaintiffs and ordered state officials to pay retroactive welfare benefits.
- The U.S. Court of Appeals for the Seventh Circuit, as the intermediate appellate court, affirmed the District Court's judgment.
- The U.S. Supreme Court, in the prior case of Edelman v. Jordan, reversed the award of retroactive benefits as a violation of the Eleventh Amendment and remanded the case.
- On remand, the District Court ordered state officials to send a specific notice to class members informing them they were entitled to past benefits.
- A panel of the U.S. Court of Appeals for the Seventh Circuit reversed the District Court's notice order.
- The U.S. Court of Appeals for the Seventh Circuit, sitting en banc, also reversed the specific notice but held that a modified, purely explanatory notice would be permissible and remanded with instructions.
- The state official, Quern (petitioner), was granted a writ of certiorari by the U.S. Supreme Court to review the Seventh Circuit's en banc decision.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a federal court order requiring state officials to send an explanatory notice to welfare recipients, informing them of available state administrative procedures for seeking wrongfully-denied past benefits, violate the Eleventh Amendment?
Opinions:
Majority - Mr. Justice Rehnquist
No, a federal court order requiring state officials to send a purely explanatory notice does not violate the Eleventh Amendment. This form of relief is permissible because it is ancillary to the prospective injunctive relief already ordered by the court and does not constitute a retroactive monetary award against the state. The notice merely informs class members of existing state administrative remedies and does not establish a federal judgment of liability against the state. The decision to pursue a claim and the ultimate determination of whether to pay retroactive benefits rest entirely with the state's agencies and courts, not the federal court. This relief falls on the permissible, prospective side of the line established in Ex parte Young, rather than the impermissible, retroactive side established in Edelman v. Jordan. The court also reaffirmed its holding in Edelman that 42 U.S.C. § 1983 does not abrogate the states' Eleventh Amendment immunity, finding that subsequent cases like Monell v. New York City Dept. of Social Services did not undermine that conclusion.
Concurring - Mr. Justice Brennan
No, the notice is permissible. While I concur in the judgment, the majority's opinion engages in a gratuitous departure from judicial practice by reaching the unnecessary question of whether a state is a 'person' under 42 U.S.C. § 1983. The Court's reaffirmation of Edelman on this point is dicta and is most likely incorrect. The decision in Monell, which held that municipalities are 'persons' under § 1983, undercut the premise of Edelman's reasoning. A proper analysis of the legislative history of the Civil Rights Act of 1871 and the context of the Fourteenth Amendment demonstrates that Congress intended for states, as 'bodies politic and corporate,' to be included as 'persons' subject to suit under § 1983, thereby abrogating their Eleventh Amendment immunity.
Concurring - Mr. Justice Marshall
No, the judgment should be affirmed. The explanatory notice is clearly ancillary to prospective relief and is therefore permissible under the Court's precedent. However, because the case can be decided on this narrow ground, it is entirely unnecessary for the Court to address the broader question of whether a state is a 'person' under § 1983. I therefore join Parts I, II, and III of Justice Brennan's opinion, which criticizes the majority for needlessly addressing this issue.
Analysis:
This case clarifies the boundary established in Edelman v. Jordan between permissible prospective relief and impermissible retroactive relief against a state under the Eleventh Amendment. It establishes that 'notice relief'—a court order requiring state officials to inform individuals of their state-law rights—is a permissible ancillary remedy that does not function as a direct monetary award. The decision reinforces that while the Eleventh Amendment bars federal courts from ordering direct compensation from a state treasury for past wrongs, it does not prevent them from ordering actions with minor, incidental administrative costs that facilitate a state's own remedial processes. The majority's strong reaffirmation of Edelman's holding that § 1983 does not abrogate state sovereign immunity, despite arguments based on Monell, signaled the Court's enduring commitment to protecting state immunity from federal damage awards.
Unlock the full brief for Quern v. Jordan