Atascadero State Hospital v. Scanlon
Citation
473 U.S. 234 (1985)
Facts
A former employee sued the Atascadero State Hospital, a California state institution, under Section 504 of the Rehabilitation Act, alleging discrimination based on his disability. California argued it had not consented to suit in federal court and was protected by the Eleventh Amendment.
Issue
Whether a state’s general participation in a federal program constitutes a waiver of Eleventh Amendment sovereign immunity sufficient to allow suit in federal court.
Holding
The Court held that California had not consented to suit; a state’s general acceptance of federal funding does not constitute a clear waiver of sovereign immunity.
Rule
Congress must make its intent to abrogate state sovereign immunity unmistakably clear in statutory language; states do not waive Eleventh Amendment immunity by accepting federal funding absent explicit consent.