Quern v. Jordan
Citation and Court
440 U.S. 332 (1979), Supreme Court of the United States
Facts
Jordan and other plaintiffs brought a class action under 42 U.S.C. § 1983 against Illinois welfare officials, seeking retroactive benefits they had been wrongly denied. The district court entered an order requiring state officials to notify class members of their potential eligibility for retroactive benefits from the state. The question was whether § 1983 abrogated the states’ Eleventh Amendment immunity, allowing federal courts to order such relief against the state.
Issue
Whether 42 U.S.C. § 1983 abrogates the Eleventh Amendment immunity of states from suit in federal court for retroactive monetary relief.
Holding
Section 1983 does not abrogate the states’ Eleventh Amendment immunity; Congress did not make a sufficiently clear statement in § 1983 to override that immunity, so suits for retroactive monetary relief against a state in federal court are barred.
Rule / Doctrine
Congress may abrogate state sovereign immunity under Section 5 of the Fourteenth Amendment, but only by an unequivocal expression of intent in the statute. Section 1983’s general language is insufficient to constitute such a clear statement of abrogation. States therefore retain Eleventh Amendment immunity from § 1983 suits for retroactive relief (damages) in federal court, though Ex parte Young remains available for prospective relief against state officers.
Significance
Quern v. Jordan is the foundational case establishing that § 1983 does not abrogate Eleventh Amendment immunity, resolving a question left open after Edelman v. Jordan (1974). It defines the outer boundary of § 1983 litigation against states and makes the Ex parte Young fiction — suing individual state officers, not the state itself, for prospective relief — the primary mechanism for vindicating federal rights against state governmental actors.