Facts
- A former Florida high school student filed a 42 U.S.C. § 1983 action in Florida state court against a local school board and school officials.
- He alleged violations of the Fourth and Fourteenth Amendments arising from a search of his car on school property and a suspension allegedly imposed without due process.
- He sought damages and injunctive relief.
- Florida trial courts otherwise entertained § 1983 suits against individual officials and entertained analogous state-law claims and tort suits against governmental entities, including school boards.
- The Florida circuit court dismissed the § 1983 claim against the school board with prejudice, treating the board as immune from § 1983 liability in state court under Florida sovereign-immunity doctrine.
Issues
- Whether a state court that otherwise has jurisdiction may apply a state-law sovereign-immunity defense to bar a § 1983 suit against a local school board when that defense would not be available in federal court.
Decision
- The Supreme Court reversed and remanded.
- A state-law “sovereign immunity” defense is not available to a local school board in a § 1983 action brought in a state court of competent jurisdiction when the defense would not be available in federal court.
- Florida’s use of sovereign immunity to categorically defeat § 1983 claims against a suable local entity conflicted with federal law and the Supremacy Clause.
Legal Principles
- State and federal courts have concurrent jurisdiction over § 1983 claims, and state courts must enforce federal law under the Supremacy Clause when they have jurisdiction.
- The adequacy of a state-law ground that precludes litigation of a federal claim is a federal question reviewed by the Supreme Court.
- Under § 1983 doctrine, States and arms of the State are not “persons” subject to § 1983 liability, but local governmental entities such as school boards generally are.
- A state may not expand immunities or employ jurisdictional rules to defeat federal causes of action against defendants whom federal law makes suable.
- A state court may not refuse to entertain a category of § 1983 claims while hearing analogous state-law actions against similar defendants; such discrimination against a federal cause of action violates the Supremacy Clause.
Conclusion
The Court held that Florida courts could not invoke state sovereign-immunity doctrine to bar a § 1983 action against a local school board that federal law treats as a suable “person,” and it required state courts of competent jurisdiction to hear such federal claims on the same terms as comparable state-law actions.