Goldman v. Southeastern Pennsylvania Transportation Authority
57 A.3d 1154
| Pa. | 2012Background
- Appellees Goldman, Wiza, Maguire, and Davis sued SEPTA for injuries sustained in the course of employment with SEPTA's Regional Rail Division under FELA in Pennsylvania state court.
- SEPTA asserted Eleventh Amendment sovereign immunity as a Commonwealth arm and moved for judgment on the pleadings and then for summary judgment.
- The MTAA statute designates SEPTA as an agency and instrumentality of the Commonwealth and provides it shall enjoy sovereign immunity, a point relied upon by the Commonwealth and SEPTA.
- The Commonwealth Court held SEPTA immune under 42 Pa.C.S. § 8521, relying on the MTAA structure, funding, and other indicators; the case was remanded for further proceedings.
- Judge Pellegrini dissented, arguing for a Fitchik-style weighing of factors and concluding SEPTA is not an arm of the Commonwealth, thus not immune.
- The Pennsylvania Supreme Court granted review to determine whether SEPTA is an arm of the Commonwealth for Eleventh Amendment purposes, applying federal arm-of-the-state doctrine.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is SEPTA an arm of the Commonwealth for Eleventh Amendment purposes? | Goldman, Wiza, Maguire, Davis: SEPTA is not a Commonwealth arm and thus not immune under the Eleventh Amendment. | SEPTA is a Commonwealth agency/instrumentality; MTAA labeling and funding history support immunity. | SEPTA is not an arm of the Commonwealth; not entitled to Eleventh Amendment immunity. |
| Does FELA exposure against SEPTA in PA courts offend Commonwealth dignity or imperil its treasury? | Immunity is inconsistent with federal law and would deprive workers of FELA remedies; Third Circuit decisions support immunity denial. | Arm-of-state analysis, including Hess/Federal Maritime, supports immunity due to Commonwealth’s interest in dignity and treasury. | FELA suits against SEPTA do not threaten Commonwealth dignity or treasury; Eleventh Amendment immunity not available to SEPTA. |
Key Cases Cited
- Hess v. Port Authority Trans-Hudson Corp., 513 U.S. 30 (1994) (Lake Country/Hess framework; state sovereignty and treasury interests guide immunity analysis)
- Lake Country Estates Inc. v. Tahoe Regional Planning Agency, 440 U.S. 391 (1979) (six indicators of immunity; Arm-of-the-state analysis begins here)
- Mt. Healthy City School Dist. v. Doyle, 429 U.S. 274 (1977) (statutory classification and control inform arm-of-state status)
- Regents of the Univ. of Cal. v. Doe, 519 U.S. 425 (1997) (legal liability to pay judgments governs arm status, not indemnification)
- Alden v. Maine, 527 U.S. 706 (1999) (sovereign immunity as fundamental sovereignty protection; explicit limits on waivers)
- Seminole Tribe v. Florida, 517 U.S. 44 (1996) (Eleventh Amendment twin purposes: state dignity and treasury protection; Congress cannot broadly abrogate without Fourteenth Amendment)
- Federal Maritime Comm’n v. South Carolina Ports Authority, 535 U.S. 743 (2002) (preeminent purpose is to protect state sovereignty; Lake Country factors not always controlling)
- Port Authority Trans-Hudson Corp. v. Port Authority of New York and New Jersey, N/A (1987) (illustrative for arm-of-state considerations; not included as an official reporter citation here)