## Facts

- Residents of a Pennsylvania state institution for persons with intellectual disabilities brought a class action alleging unsafe and inhumane conditions.
- Plaintiffs sued the institution and multiple state officials responsible for institutional and community services.
- Plaintiffs asserted federal constitutional and statutory claims and a state-law claim under Pennsylvania’s Mental Health and Mental Retardation Act of 1966 (MH/MR Act).
- The federal district court ordered broad injunctive relief, including community placements and reforms, relying in part on the MH/MR Act.
- After an earlier Supreme Court decision eliminated the primary federal statutory basis relied on by the court of appeals, the litigation continued with injunctive relief supported by the MH/MR Act as a pendent state-law ground.
- The court of appeals held the Eleventh Amendment did not bar federal adjudication and enforcement of the pendent state-law claim against state officials.
- The Supreme Court granted review to resolve whether sovereign immunity permits federal injunctive orders directing state officials to comply with state law.

## Issues

1. Whether the Eleventh Amendment permits a federal court to grant prospective injunctive relief requiring state officials to conform their conduct to state law.
2. Whether the *Ex parte Young* exception to sovereign immunity extends to pendent state-law claims in a federal-question case.
3. Whether pendent jurisdiction can supply authority to adjudicate and enforce state-law obligations against state officials notwithstanding the Eleventh Amendment.

## Decision

- The Supreme Court reversed the court of appeals.
- The Court held that the Eleventh Amendment barred the federal court from ordering state officials to comply with the MH/MR Act.
- The Court ruled that *Ex parte Young* authorizes prospective relief only to end ongoing violations of federal law, not to enforce state law in federal court.
- The Court rejected the argument that pendent jurisdiction can override sovereign immunity, holding that no jurisdictional doctrine permits circumvention of the Eleventh Amendment.
- The Court concluded that even purely prospective injunctive relief is barred when its legal basis is state law and the state is the real party in interest.

## Legal Principles

- The Eleventh Amendment limits federal judicial power by barring suits that, in substance, seek relief against a state, including suits for injunctive relief where the state is the real party in interest.
- *Ex parte Young* permits suits against state officials for prospective relief only to remedy ongoing violations of federal law; it does not authorize federal courts to compel compliance with state law.
- Pendent jurisdiction cannot authorize federal courts to adjudicate and enforce state-law claims against state officials when the Eleventh Amendment would otherwise bar the relief.
- The prospective/retroactive relief distinction developed for federal-law claims does not permit prospective federal decrees compelling state-law compliance.
- Enforcement of state-law duties against state officials is for state courts absent a valid federal-law basis that fits within an immunity exception.

## Conclusion

The Court held that sovereign immunity prevents federal courts from issuing injunctive orders directing state officials to comply with state law, and that neither *Ex parte Young* nor pendent jurisdiction permits federal enforcement of state-law obligations against a state or its officials.


Pennhurst State Sch. & Hosp. v. Halderman, 465 U.S. 89 (1984)