Facts
- Ray Will, an employee of the Michigan Department of State Police, sought a promotion to a data systems analyst position.
- Will alleged he was denied the promotion for an improper, politically motivated reason tied to his brother’s prior student activism and a police-maintained file.
- Will filed suit under 42 U.S.C. § 1983 against the Michigan Department of State Police and the Director of the Michigan State Police in the Director’s official capacity, seeking relief for alleged constitutional violations.
- A state trial court entered judgment for Will, treating both the Department and the Director as “persons” under § 1983.
- The Michigan appellate courts concluded that the State was not a “person” under § 1983 and ultimately held that an official sued in an official capacity was also not a “person.”
- The U.S. Supreme Court granted review to decide whether States and official-capacity state officers are “persons” under § 1983.
Issues
- Whether a State or a state agency is a “person” subject to suit for damages under 42 U.S.C. § 1983.
- Whether a state official sued in an official capacity is a “person” subject to suit for damages under 42 U.S.C. § 1983.
- Whether § 1983 permits official-capacity suits against state officials for prospective injunctive relief.
Decision
- The Supreme Court affirmed the judgment that neither a State nor state officials acting in their official capacities are “persons” within the meaning of § 1983 for damages actions.
- The Court reasoned that, in ordinary usage, “person” does not include a State, and Congress did not make an unmistakably clear statement in § 1983 to impose such liability on States.
- The Court relied on interpretive principles protecting the state–federal balance and the background understanding that § 1983 did not abrogate well-established immunities, including sovereign immunity.
- The Court held that an official-capacity suit is treated as a suit against the official’s office and therefore against the State itself; damages claims in that posture are barred because the State is not a § 1983 “person.”
- The Court clarified that state officials sued in their official capacities for prospective injunctive relief remain suable under § 1983 because such actions are not treated as actions against the State.
Legal Principles
- States and state agencies are not “persons” subject to damages liability under 42 U.S.C. § 1983.
- State officials sued in their official capacities are not “persons” under § 1983 when the plaintiff seeks monetary damages, because the suit is treated as one against the State.
- Congress must speak with unmistakable clarity when altering the constitutional balance between States and the Federal Government; general statutory language is not enough to impose § 1983 damages liability on States.
- Background immunities, including sovereign immunity, inform § 1983’s scope absent a clear statutory displacement.
- Municipalities may be “persons” under § 1983, but that rule does not extend to States or arms of the State.
- Official-capacity suits seeking prospective injunctive relief against state officials may proceed under § 1983.
Conclusion
The Court held that § 1983 does not authorize damages actions against States, state agencies, or state officials sued in their official capacities, while leaving open § 1983 official-capacity actions for prospective injunctive relief against state officials.