## Facts

- California and Nevada formed an interstate compact, approved by Congress, creating the Tahoe Regional Planning Agency (TRPA) to regulate development and conserve resources in the Lake Tahoe Basin.
- The compact empowered TRPA to adopt and enforce a regional plan addressing land use, transportation, conservation, recreation, and public services.
- Basin property owners alleged TRPA adopted a land-use ordinance that destroyed the value of their property, asserting Fifth and Fourteenth Amendment violations.
- The owners sought damages and equitable relief, alleging TRPA and its officials acted under color of state law and were suable under 42 U.S.C. § 1983, with jurisdiction under 28 U.S.C. § 1343.
- The district court dismissed, reasoning TRPA lacked condemnation power and the individual members and executive officer were immune.
- The Ninth Circuit held § 1983 and § 1343 unavailable because congressional consent made the compact federal law, held TRPA immune under the Eleventh Amendment, and applied absolute/qualified immunities to officials depending on legislative or executive conduct.

## Issues

1. Whether TRPA and its officials acted under color of state law, permitting a § 1983 action and § 1343 jurisdiction, despite congressional approval of the compact.
2. Whether TRPA, as a bi-state compact entity, was entitled to Eleventh Amendment immunity as an arm of the compacting states.
3. How immunity doctrines applied to TRPA’s individual members and executive officer in light of TRPA’s status.

## Decision

- The Supreme Court held the complaint stated a cause of action under § 1983 and properly invoked jurisdiction under § 1343.
- Congressional consent to the compact did not prevent characterizing TRPA’s conduct as under color of state law.
- TRPA was not entitled to Eleventh Amendment immunity.
- The Court reversed the Ninth Circuit on the unavailability of § 1983 and on TRPA’s Eleventh Amendment immunity and remanded for further proceedings.

## Legal Principles

- Congressional approval of an interstate compact does not, by itself, convert the compact entity into a purely federal actor for § 1983 purposes.
- A compact agency may act under color of state law where its membership, financing, and control are rooted in state and local governments, and the states retain meaningful authority (including withdrawal rights).
- A bi-state compact entity is not automatically an arm of the state for Eleventh Amendment purposes; immunity depends on the entity’s structure, financial arrangements, and relationship to the compacting states.
- Officials of regional or local governmental bodies remain subject to ordinary § 1983 immunity doctrines; those doctrines do not depend on extending state sovereign immunity to the agency.

## Conclusion

The Court permitted § 1983 claims against a congressionally approved bi-state planning agency and rejected Eleventh Amendment immunity for the agency, requiring courts to assess a compact entity’s state ties and fiscal responsibility rather than treating it as a state by default.


Lake Country Estates, Inc. v. Tahoe Reg'l Planning Agency, 440 U.S. 391 (1979)