Facts
- Congress amended Title VII in 1972 to cover state and local governments as employers and to authorize private suits for monetary relief, invoking its enforcement power under § 5 of the Fourteenth Amendment.
- Present and retired male employees of Connecticut sued state officials who administered the state employees’ retirement plan.
- The plaintiffs alleged sex-based discrimination in certain provisions of Connecticut’s statutory retirement benefits in violation of Title VII.
- The plaintiffs sought prospective injunctive relief, retroactive benefits (backpay), and attorney’s fees authorized by Title VII.
- The federal district court found a Title VII violation and entered prospective injunctive relief against state officials but denied backpay and attorney’s fees as barred by the Eleventh Amendment because the awards would be paid from the state treasury.
- The Second Circuit affirmed the denial of backpay but reversed on attorney’s fees, treating fees as permissible costs with only an ancillary fiscal effect.
- The Supreme Court granted review to determine whether the Eleventh Amendment barred backpay and attorney’s fees authorized by Title VII against a state employer.
Issues
- Whether the Eleventh Amendment bars a retroactive monetary award (backpay) against a state when Congress has authorized such relief in Title VII pursuant to § 5 of the Fourteenth Amendment.
- Whether the Eleventh Amendment bars an award of attorney’s fees against a state under Title VII.
- Whether, and under what conditions, Congress may abrogate state sovereign immunity when legislating under § 5 of the Fourteenth Amendment.
Decision
- The Supreme Court held that Title VII’s 1972 amendments validly authorized awards of backpay and attorney’s fees against state employers.
- The Court concluded that state sovereign immunity under the Eleventh Amendment is limited when Congress acts pursuant to § 5 of the Fourteenth Amendment.
- The Court distinguished prior Eleventh Amendment limits on retroactive relief by emphasizing the presence of clear congressional authorization to subject states to suit and monetary liability.
- The Court affirmed in part and reversed in part the lower court rulings to allow both backpay and attorney’s fees.
Legal Principles
- Congress may abrogate state sovereign immunity when it legislates pursuant to § 5 of the Fourteenth Amendment.
- The Eleventh Amendment’s bar on retroactive monetary relief is not controlling where Congress, acting under § 5, has clearly authorized private suits for money awards against states.
- The “threshold” inquiry in this setting is whether Congress unmistakably authorized suits and remedies against states; where it did, courts may award statutory monetary relief that reaches the state treasury.
- Under Title VII as amended, backpay and reasonable attorney’s fees may be awarded against state employers as remedies for unlawful employment discrimination.
Conclusion
Because Congress, acting under § 5 of the Fourteenth Amendment, expressly subjected states to Title VII liability and authorized monetary remedies, the Eleventh Amendment did not bar awards of backpay or attorney’s fees against Connecticut officials administering the state retirement plan.