## Facts

- Congress granted Mississippi “Sixteenth Section” lands in each township to be held in trust for public schools, but this grant did not include lands in northern Mississippi then held by the Chickasaw Nation.
- After the Chickasaws ceded the region, Congress provided “Lieu Lands” to substitute for missing Sixteenth Section lands, vesting title in the State for use of schools within the Chickasaw Cession counties.
- Mississippi sold the Lieu Lands and invested the proceeds in railroad loans that were later lost; the principal was never restored.
- Under current state law, income from remaining Sixteenth Section and Lieu Lands is credited to the school districts tied to the particular lands, producing substantially higher per-pupil land-income in districts outside the Chickasaw Cession.
- Chickasaw Cession districts receive only a state “interest” appropriation reflecting a notional return on the long-lost principal, resulting in a persistent funding disparity.
- Local school officials and schoolchildren sued state officials, alleging (1) breach of trust/property obligations tied to the school lands and (2) denial of equal protection and a minimally adequate education due to the disparity.
- The federal district court dismissed on Eleventh Amendment grounds; the Fifth Circuit affirmed, while indicating the equal protection claim was not barred.

## Issues

1. Whether claims seeking restoration or replacement of the lost Chickasaw Cession school-land trust corpus (or its monetary equivalent) are barred by the Eleventh Amendment as retrospective relief against the State.
2. Whether an equal protection challenge to ongoing disparities in the present distribution of school-land benefits is barred by the Eleventh Amendment or may proceed as prospective relief against state officials.
3. Whether the complaint states a cognizable federal claim based on federal land-grant trust/property rights, as opposed to state-law trust obligations.
4. Whether the allegations of unequal school-land benefits and inadequate education state an equal protection claim sufficient to survive dismissal, and what standard of review applies.

## Decision

- The Court held that the trust/corpus-restoration claims were barred by the Eleventh Amendment because the requested relief would require the State to use its own resources to replace assets lost in the past.
- The Court held that the equal protection claim was not barred to the extent it challenged an ongoing disparity in current benefits and sought forward-looking relief to change present administration.
- The Court was skeptical that the land-grant history created an ongoing federally enforceable property/trust right to the lost corpus for the asserted local beneficiaries, treating the asserted “perpetual” trust obligation as largely a matter of state law.
- The Court remanded for further proceedings on the equal protection claim, including whether the current disparity is rationally related to a legitimate state interest and whether federal law mandates the unequal distribution.

## Legal Principles

- The Eleventh Amendment bars suits that, in substance, seek retrospective compensation from the state treasury, even when styled as equitable relief to restore a trust corpus.
- Under Ex parte Young, suits against state officials for prospective injunctive or declaratory relief to end an ongoing constitutional violation are not barred by state sovereign immunity.
- A claim framed as a present, continuing unequal distribution of state-administered benefits may qualify as prospective relief, distinct from a demand to remedy past loss.
- Education is not a fundamental right under the Federal Constitution; equal protection challenges to school-funding or benefit disparities generally proceed under rational-basis review absent a suspect classification.

## Conclusion

The Court distinguished between barred retrospective claims demanding replacement of long-lost school-land trust assets and a nonbarred, prospective equal protection challenge to an ongoing disparity in current school-land benefits, allowing only the latter to proceed on remand for rational-basis review and related inquiries.


Papasan v. Allain, 478 U.S. 265 (1986)