## Facts

- Hamid R. Kashani, an Iranian national, was dismissed from Purdue University’s Ph.D. program in electrical engineering during the period of the Iranian hostage crisis.
- Kashani filed a 42 U.S.C. § 1983 action alleging his dismissal was based on national-origin discrimination, violating the Equal Protection Clause.
- Defendants included Purdue University; its trustees and president in their official capacities; and graduate school officials and Ph.D. review committee members in official and individual capacities.
- Kashani sought monetary damages and injunctive relief in the form of reinstatement to the doctoral program.
- The district court dismissed damages claims against Purdue and against officials in their official capacities for lack of subject-matter jurisdiction based on Eleventh Amendment immunity.
- The district court also dismissed all claims for injunctive relief on Eleventh Amendment grounds.
- The parties stipulated to dismissal of the remaining individual-capacity damages claims to permit an immediate appeal.
- On appeal, Kashani challenged only (1) dismissal of all claims against Purdue and (2) dismissal of official-capacity claims for injunctive relief against Purdue officials.

## Issues

1. Whether Purdue University qualifies as an “arm of the state” entitled to Eleventh Amendment immunity, barring § 1983 claims against the university and official-capacity claims for monetary relief.
2. Whether the Eleventh Amendment bars a § 1983 suit against Purdue officials in their official capacities for prospective injunctive relief, specifically reinstatement to an academic program.

## Decision

- The Seventh Circuit held Purdue University is an arm of the State of Indiana and is protected by Eleventh Amendment immunity.
- The court affirmed dismissal of all claims against Purdue University.
- The court affirmed dismissal of official-capacity claims seeking monetary relief against Purdue officials.
- The court held the Eleventh Amendment does not bar official-capacity claims seeking prospective injunctive relief requiring reinstatement.
- The court reversed dismissal of the reinstatement claims against officials in their official capacities and remanded for further proceedings limited to that prospective relief.

## Legal Principles

- A state-affiliated public university may be treated as an arm of the state when state control and integration are substantial, triggering Eleventh Amendment immunity in federal court absent waiver or valid congressional abrogation.
- The Eleventh Amendment bars § 1983 suits for damages and other retrospective monetary relief against a state, its arms, and state officials sued in their official capacities when the state is the real party in interest.
- Under the Ex parte Young doctrine, plaintiffs may sue state officials in their official capacities for prospective injunctive relief to end an ongoing violation of federal law.
- Reinstatement to a position or program is generally treated as prospective injunctive relief and therefore is not barred by the Eleventh Amendment when sought against appropriate state officials.

## Conclusion

The court concluded that Purdue shares Indiana’s sovereign immunity, foreclosing § 1983 damages claims against the university and official-capacity damages claims against its officers, but permitted the case to proceed against university officials for prospective injunctive relief seeking reinstatement to the doctoral program.


Kashani v. Purdue Univ., 813 F.2d 843 (7th Cir. 1987)