## Facts

- Igor Mazur, a former physics laboratory technician at the University of Idaho, claimed he was wrongfully fired from his job.
- Mazur filed suit in Idaho state court (Second Judicial District, Latah County) against members of the Idaho State Board of Education and University of Idaho officials, naming them in their official roles.
- The complaint included claims under 42 U.S.C. § 1983 and sought relief that included monetary damages and reinstatement to his university position.
- Acting through a deputy, the Idaho Attorney General removed the case to the U.S. District Court for the District of Idaho on the basis of federal-question jurisdiction.
- Mazur filed a petition seeking denial of removal (treated as a motion to remand), arguing that the action was, in substance, a suit against the State of Idaho and therefore barred in federal court by the Eleventh Amendment.
- Defendants opposed remand and also filed a motion to dismiss.
- A key question for Eleventh Amendment purposes was whether a judgment against the university and board officials would affect the state treasury; the record contained no concrete information quantifying any budgetary impact.
- The district court analyzed the requested relief in practical terms, including whether reinstatement would require payment of salary from state-appropriated funds.

## Issues

1. Whether Mazur’s § 1983 suit against University of Idaho and State Board of Education officials in their official capacities is, in effect, a suit against the State of Idaho barred by the Eleventh Amendment in federal court.
2. Whether Idaho waived Eleventh Amendment immunity (including by the Attorney General’s removal of the action to federal court or by state statute), so that the federal court could keep the case.
3. Whether Mazur’s request for reinstatement, although framed as injunctive relief, is barred because it would operate like monetary relief paid from state funds.

## Decision

- The court concluded that the action against the university and board officials in their official capacities was a suit against the State of Idaho for Eleventh Amendment purposes.
- The court held that Eleventh Amendment immunity barred Mazur’s § 1983 damages claims against the state (and state officials sued in their official capacities).
- The court further held that Mazur’s reinstatement request, though labeled prospective injunctive relief, would in practical effect require salary payments and thus would impact the state treasury; the court treated that claim as barred as well.
- The court rejected arguments that federal-question jurisdiction, by itself, allowed the case to proceed in federal court despite Eleventh Amendment immunity.
- The court found no valid waiver of Eleventh Amendment immunity by Idaho, including no waiver arising from removal by the Attorney General.
- Because the Eleventh Amendment deprived the federal court of jurisdiction, the court remanded the case to Idaho state court under 28 U.S.C. § 1447(c).
- Defendants’ pending motion to dismiss was denied as moot.

## Legal Principles

- A suit against state officials in their official capacities is treated as a suit against the state when the requested relief would be satisfied from, or would affect, the state treasury.
- The Eleventh Amendment bars federal-court jurisdiction over suits against a state by private parties unless the state clearly waives immunity or Congress validly abrogates it.
- Claims for damages against a state under 42 U.S.C. § 1983 are barred by the Eleventh Amendment absent waiver or abrogation.
- Although prospective injunctive relief may fall outside Eleventh Amendment immunity in some settings, a court looks to the practical effect of the relief; relief that effectively requires payments from state funds may be treated as barred.
- The existence of federal-question jurisdiction does not override Eleventh Amendment immunity; immunity is an independent constitutional limit on the federal judicial power.
- Waiver of Eleventh Amendment immunity must be clear; removal to federal court does not, by itself, establish waiver where state law does not authorize the removing official to waive the state’s immunity.
- When Eleventh Amendment immunity eliminates federal jurisdiction over a removed action, remand to state court is required.

## Conclusion

The District of Idaho held that Mazur’s § 1983 action against University of Idaho and State Board of Education officials in their official capacities was, in effect, a suit against the State of Idaho and was barred in federal court by the Eleventh Amendment. The court also treated Mazur’s reinstatement request as barred because it would require salary payments from state funds. Finding no valid waiver of immunity, including no waiver from removal, the court remanded the case to Idaho state court and deemed the defendants’ motion to dismiss moot.


Mazur v. Hymas, 678 F. Supp. 1473 (1988)