Coleman v. Court of Appeals of Maryland
132 S. Ct. 1327
| SCOTUS | 2012Background
- Coleman, a Maryland state court employee, sued alleging FMLA self-care leave violation and damages.
- FMLA § 2612(a)(1)(D) provides up to 12 weeks of unpaid leave for employee’s serious health condition.
- FMLA also has family-care provisions (e.g., § 2612(a)(1)(C)) previously held to abrogate state immunity in Hibbs.
- District court and Fourth Circuit held the self-care provision does not validly abrogate state sovereign immunity for damages.
- The Court analyzed § 5 of the Fourteenth Amendment to determine if Congress could validly abrogate immunity for this provision.
- The Court ultimately affirmed the judgment against Coleman, upholding state immunity for damages under the self-care provision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Can FMLA self-care (D) abrogate state immunity for damages under §5? | Coleman argues Congress validly abrogated immunity under §5. | States retain immunity unless a valid §5 remedy is tailored to a pattern of violations. | No; self-care damages abrogation fails §5 congruence. |
| Does Hibbs framework apply to self-care (D) as a gender-discrimination remedy? | Self-care tied to gender discrimination through pregnancy and health care needs. | Self-care lacks proven pattern of sex-based state discrimination and is not congruent with Hibbs. | Not applicable; self-care not a valid Hibbs-type remedy. |
| Is there a nexus between self-care and gender discrimination sufficient for §5? | Self-care serves to counteract gender-based workplace discrimination. | Evidence does not show a constitutional violation pattern linked to self-care leave. | Nexus insufficient; §5 not satisfied. |
| Can states waive immunity or provide a parallel state-law remedy instead? | States could waive immunity or create state-law actions to address discrimination. | Such waivers are for the States to decide; Congress cannot compel damages liability here. | Yes; states may waive immunity or enact parallel remedies. |
Key Cases Cited
- Florida Prepaid Postsecondary Ed. Expense Bd. v. College Savings Bank, 527 U. S. 627 (1999) (congruence and proportionality in §5 enforcement; remedial limits)
- City of Boerne v. Flores, 521 U. S. 507 (1997) (congruence and proportionality standard for §5)
- Kimel v. Florida Bd. of Regents, 528 U. S. 62 (2000) (limits of §5 enforcement in non-suspect classifications)
- Nevada Dept. of Human Resources v. Hibbs, 538 U. S. 721 (2003) (valid abrogation for family-care leave §2612(a)(1)(C))
- Board of Trustees of Univ. of Ala. v. Garrett, 531 U. S. 356 (2001) (§5 enforcement power and pattern of constitutional violations)
- Aiello v. California Dept. of Industrial Relations, 417 U. S. 484 (1974) (pregnancy discrimination as sex discrimination under constitutional analysis)
- Nevada Dept. of Human Resources v. Hibbs, 538 U. S. 721 (2003) (Hibbs cited for pattern-based §5 abrogation analysis)