Edelman v. Jordan

Joel EDELMAN, Director of Illinois Department of Public Aid, etc., Petitioner, v. John JORDAN et al.
415 U.S. 651 (1974) |
SCOTUS decided 1974-03-25
Jurisdiction level:

Reversing the lower court, the Supreme Court held that the Eleventh Amendment barred the award of retroactive benefits by the state of Illinois under federal-state programs of Aid to the Aged, Blind, and Disabled.

Result: Loss
Importance:

Laurence Baum, The Oxford Guide to United States Supreme Court Decisions: “The impact of Edelman has been limited by more recent decisions that allow Congress to overcome the immunity of states from lawsuits through its powers to enforce the Fourteenth Amendment (Fitzpatrick v. Bitzer, 1976) and to regulate commerce (Pennsylvania v. Union Gas Co., 1989). Because of the breadth of those powers, these decisions significantly narrow state immunity.”


Law type: Civil
Topic(s): Equal protection, Public assistance, Retroactive benefits, and Sovereign immunity
State of origin: IL
Attorneys:

Sheldon Roodman, Chicago, Ill., for respondents. (Legal Assistance Foundation of Metropolitan Chicago)


Others involved:
Organization role: Sponsor

Last modified: 2020-04-02 11:27
Case internal grade: A | Case internal status: OK |
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CASE DETAILS

(The syllabus is not part of the opinion, but is a summary prepared by the court reporter as a convenience.)

Syllabus

Respondent brought this class action for injunctive and declaratory relief against the Illinois officials administering the federal-state programs of Aid to the Aged, Blind, and Disabled (AABD), which are funded equally by the State and Federal Governments, contending that they were violating federal law and denying equal protection of the laws by following state regulations that did not comply with the federal time limits within which participating States had to process and make grants with respect to AABD applications. The District Court by a permanent injunction required compliance with the federal time limits and also ordered the state officials to release and remit AABD benefits wrongfully withheld to all persons found eligible who had applied therefor between July 1, 1968, the date of the federal regulations, and April 16, 1971, the date of the court’s preliminary injunction. The Court of Appeals affirmed, rejecting the state officials’ contentions that the Eleventh Amendment barred the award of the retroactive benefits and that the judgment of inconsistency between federal regulations and state provisions could be given only prospective effect. Held: The Eleventh Amendment of the Constitution bars that portion of the District Court’s decree that ordered retroactive payment of benefits. Pp. 658—678.

(a) A suit by private parties seeking to impose a liability payable from public funds in the state treasury is foreclosed by the Amendment if the State does not consent to suit. Pp. 662—663.

(b) The Court of Appeals erred in holding that Ex parte Young, 209 U.S. 123, 28 S.Ct. 441, 52 L.Ed. 714, which awarded only prospective relief, did not preclude the retroactive monetary award here on the ground that it was an ‘equitable restitution,’ since that award, though on its face directed against the state official individually, as a practical matter could be satisfied only from the general revenues of the State and was indistinguishable from an award of damages against the State. Ford Motor Co. v. Department of Treasury, 323 U.S. 459, 65 S.Ct. 347, 89 L.Ed. 389, followed. Shapiro v. Thompson, 394 U.S. 618, 89 S.Ct. 1322, 22 L.Ed.2d 600; State Dept. of Health and Rehabilitation Services v. Zarate, 407 U.S. 918, 92 S.Ct. 2462, 32 L.Ed.2d 803; Sterrett v. Mothers’ & Children’s Rights Organization, 409 U.S. 809, 93 S.Ct. 68, 34 L.Ed.2d 70; Wyman v. Bowens, 397 U.S. 49, 90 S.Ct. 813, 25 L.Ed.2d 38, disapproved to extent that their holdings do not comport with the holding in the instant case on the Eleventh Amendment issue. Pp. 663—771.

(c) The State of Illinois did not waive its Eleventh Amendment immunity and consent to the bringing of respondent’s suit by participating in the federal AABD program. Parden v. Terminal R. Co., 377 U.S. 184, 84 S.Ct. 1207, 12 L.Ed.2d 233, and Petty v. Tennessee-Missouri Bridge Comm’n., 359 U.S. 275, 79 S.Ct. 785, 3 L.Ed.2d 804, distinguished. Nor does the mere fact that a State participates in a program partially funded by the Federal Government manifest consent by the State to be sued in federal courts. Pp. 671—674.

(d) The Court of Appeals properly considered the Eleventh Amendment defense, which the state officials did not assert in the District Court, since that defense partakes of the nature of a jurisdictional bar. Ford Motor Co. v. Department of Treasury, supra. Pp. 677—678.

472 F.2d 985, 7 Cir., reversed and remanded.

From the opinion

Mr. Justice REHNQUIST delivered the opinion of the Court.

Respondent John Jordan filed a complaint in the United States District Court for the Northern District of Illinois, individually and as a representative of a class, seeking declaratory and injunctive relief against two former directors of the Illinois Department of Public Aid, the director of the Cook County Department of Public Aid, and the comptroller of Cook County. Respondent alleged that these state officials were administering the federal-state programs of Aid to the Aged, Blind, or Disabled (AABD) in a manner inconsistent with various federal regulations and with the Fourteenth Amendment to the Constitution.
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Respondent’s complaint charged that the Illinois defendants, operating under those regulations, were improperly authorizing grants to commence only with the month in which an application was approved and not including prior eligibility months for which an applicant was entitled to aid under federal law. The complaint also alleged that the Illinois defendants were not processing the applications within the applicable time requirements of the federal regulations; specifically, respondent alleged that his own application for disability benefits was not acted on by the Illinois Department of Public Aid for almost four months. Such actions of the Illinois officials were alleged to violate federal law and deny the equal protection of the laws. Respondent’s prayer requested declaratory and injunctive relief, and specifically requested ‘a permanent injunction enjoining the defendants to award to the entire class of plaintiffs all AABD benefits wrongfully withheld.’
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