Pennhurst State School v. Halderman
Citation
465 U.S. 89 (1984)
Facts
Patients at Pennhurst State School and Hospital in Pennsylvania sued state officials seeking injunctive relief based on both federal constitutional claims and Pennsylvania state law claims. The case reached the Supreme Court on the question of whether the Eleventh Amendment barred the federal court from ordering state officials to comply with state law.
Issue
Whether the Eleventh Amendment bars federal courts from ordering state officials to conform their conduct to state law.
Holding
The Court held that the Eleventh Amendment bars suits in federal court against state officials for violations of state law, even when the suit is styled as seeking prospective injunctive relief.
Rule
The Eleventh Amendment bars suits in federal court against state officials for violations of state law (the “Pennhurst doctrine”); Ex parte Young does not extend to state-law claims.