Gloria Jane Miller v. Advantage Behavioral Health Systems
677 F. App'x 556
11th Cir.2017Background
- Gloria Jane Miller sued Advantage Behavioral Health Systems (a Georgia community service board, “CSB”) under the ADEA, alleging age-based wrongful termination in 2010. Advantage moved to dismiss on Eleventh Amendment immunity grounds after discovery; the district court denied the motion.
- Advantage is created by Georgia statute, labeled an "instrumentality of the state" but also statutorily given the "same immunity as provided for counties," and is overseen at a high level by the Georgia Department of Behavioral Health and Developmental Disabilities (DBHDD).
- Day-to-day governance, hiring/firing, budgeting, and personnel decisions are controlled by locally appointed Governing Boards and an Executive Director; the State’s role is limited to high-level oversight and approval of the Executive Director’s selection and compensation.
- Advantage asserted it was an “arm of the State” and therefore entitled to Eleventh Amendment immunity from Miller’s ADEA claim; the district court rejected that claim and this court reviews that denial de novo.
- The Eleventh Circuit applied the four-factor Manders test (state law definition; state control over the function; source of funding; who pays judgments) focused on the specific function at issue—hiring and firing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Advantage is an "arm of the State" entitled to Eleventh Amendment immunity for Miller's termination | Miller: Advantage acted independently in personnel decisions and is not a state arm | Advantage: CSBs are statutory state instrumentalities and receive state funding, so they qualify as state arms | Court: Not an arm of the State; immunity denied |
| How Georgia law classifies CSBs for Manders factor 1 | Miller: State statutory labels and Youngblood don't make Advantage an arm for federal immunity | Advantage: Statute calls CSBs "instrumentalities" and Georgia Supreme Court treated CSBs as state agencies under state law | Held: Georgia law is mixed but Youngblood suggests state-agency status; factor only weakly favors immunity and does not control outcome |
| Whether the State controls hiring/firing (Manders factor 2) | Miller: Local Governing Board and Executive Director control personnel; state control is limited | Advantage: Commissioner approves Executive Director and state sets some standards, implying meaningful control | Held: Factor weighs against immunity—state involvement is high-level only; local control over day-to-day personnel predominates |
| Whether the State would ultimately bear liability for judgments (Manders factor 4) | Miller: Statute disclaims state liability for CSB debts; State unlikely obligated to prop up CSB | Advantage: An adverse judgment would indirectly implicate state treasury and service provision in the region | Held: Factor strongly against immunity—Georgia law disclaims state liability and Advantage failed to show the State would be forced to absorb judgments |
Key Cases Cited
- Manders v. Lee, 338 F.3d 1304 (11th Cir. 2003) (sets four-factor test for arm-of-the-state analysis under the Eleventh Amendment)
- Lightfoot v. Henry County School District, 771 F.3d 764 (11th Cir. 2014) (assessing Manders factors and emphasizing local control over state-control indicators)
- Kimel v. Florida Board of Regents, 528 U.S. 62 (U.S. 2000) (holding Congress did not validly abrogate state Eleventh Amendment immunity under the ADEA)
- Pellitteri v. Prine, 776 F.3d 777 (11th Cir. 2015) (finding state control over a sheriff’s office supported immunity where the State tightly regulated hiring and discipline)
- U.S. ex rel. Lesinski v. South Fla. Water Mgmt. Dist., 739 F.3d 598 (11th Cir. 2014) (considering whether state would need to increase appropriations to cover a water district’s liabilities)
- Garrett v. University of Alabama at Birmingham Board of Trustees, 344 F.3d 1288 (11th Cir. 2003) (standard of review: de novo for denial of sovereign-immunity defense)