Matthew Jones v. Sussex Correctional Institute
17-2490
| 3rd Cir. | Dec 5, 2017Background
- Pro se prisoner Matthew Jones sued the Family Court of Delaware and later the Sussex Correctional Institute, alleging numerous crimes (enslavement, identity theft, assault, rape, etc.) and seeking $2 billion in damages related to his 2014 arrest and detention.
- District Court dismissed the original complaint under 28 U.S.C. § 1915(e)(2)(B)(iii) based on Eleventh Amendment immunity and gave Jones leave to amend.
- Jones filed an amended complaint naming only the Sussex Correctional Institute; the District Court again dismissed under § 1915(e)(2)(B)(iii) as the state correctional institution is immune.
- Jones appealed, arguing the Constitution eliminated state sovereign immunity and that Eleventh Amendment precedent should be overruled; he also claimed various statutes waived sovereign immunity.
- The Third Circuit reviewed de novo whether the defendant is immune and affirmed dismissal, concluding the correctional institute is a state agency entitled to Eleventh Amendment immunity and no abrogation, waiver, or proper individual-capacity claim applies.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Eleventh Amendment bars suit against Sussex Correctional Institute | Jones: Eleventh Amendment does not bar suits by U.S. citizens; sovereign immunity was eliminated by the Constitution | Institute/State: The Institute is a state agency and protected by Eleventh Amendment immunity | Held: Dismissal affirmed; Institute is immune as the state is the real party in interest |
| Whether Supreme Court Eleventh Amendment precedent may be overruled here | Jones: Court should discard/reject Eleventh Amendment precedent | Respondent: Binding Supreme Court precedent controls; appeals court cannot overrule Supreme Court | Held: Court refused to overrule; precedent remains controlling |
| Whether any statutory abrogation or waiver applies | Jones: Various federal statutes waive state sovereign immunity | Respondent: Cited statutes do not abrogate state immunity for these claims; many statutes cited do not create private rights | Held: No applicable congressional abrogation or state waiver; statutes cited irrelevant or inapplicable |
| Whether claims could proceed against non-immune individual defendants | Jones: Amended complaint names non-immune individuals within text | Respondent: Only the Institute is a named defendant; individuals are not parties | Held: No individual defendants are properly named; District Court had given leave to amend to name individuals if Jones wished |
Key Cases Cited
- Edelman v. Jordan, 415 U.S. 651 (Sup. Ct.) (Eleventh Amendment bars suits for retroactive relief against an unconsenting state)
- Fitchik v. New Jersey Transit Rail Operations, 873 F.2d 655 (3d Cir. en banc) (state agencies immune where the state is the real party in interest)
- MCI Telecommunications Corp. v. Bell Atlantic Pa., 271 F.3d 491 (3d Cir.) (enumerating Eleventh Amendment exceptions: congressional abrogation, state waiver, and suits for prospective relief against officers)
- Alden v. Maine, 527 U.S. 706 (Sup. Ct.) (structural basis for state sovereign immunity under the Constitution)
- Hans v. Louisiana, 134 U.S. 1 (Sup. Ct.) (early affirmation of state sovereign immunity)