844 N.W.2d 668
Iowa2014Background
- Lee, a State employee, sued the State of Iowa and Polk County Clerk of Court under the FMLA self-care provision for wrongful termination and sought reinstatement, back wages, and related relief.
- The district court originally ordered reinstatement and back pay; on appeal, sovereign immunity barred monetary damages but injunctive relief under Ex parte Young remained at issue.
- On remand after Lee I, the district court reinstated Lee and awarded wages from the date of the 2007 reinstatement as a form of injunction.
- This court reversed the noninjunctive relief and remanded to determine what relief could be granted under Ex parte Young within the framework of immunity.
- The issues on remand included whether Ex parte Young relief could be pursued in state court, whether Lee named a proper party, and whether wage awards were prospective relief.
- The current Iowa Supreme Court affirmance addresses the availability and scope of Ex parte Young relief and the timing of prospective earnings payments.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is Ex parte Young relief available in state court? | Lee sought prospective injunctive relief against a state official. | State immunity precluded Ex parte Young in state court. | Yes; Ex parte Young applies in state courts. |
| Was Lee’s party naming sufficient for Ex parte Young relief? | Lee sued the Clerk of Court, a state official, so proper for official-capacity relief. | Lee did not name a specific official by name, only the office. | Lee named a proper party; official-capacity relief permitted. |
| Was Lee’s prayer for relief adequate to obtain Ex parte Young relief? | Lee sought reinstatement and related equitable relief under FMLA and Ex parte Young. | Plaintiff failed to explicitly plead Ex parte Young or reinstatement. | Reinstatement litigated by consent; pleadings sufficient under notice pleading. |
| Does backpay from the original 2007 reinstatement date constitute prospective relief? | Lost wages from 2007 are prospective as they arise from court-imposed obligation to reinstate. | Backpay is retroactive monetary relief barred by immunity. | October 29, 2007, as the prospective-relief start date; backpay post-stay permissible as prospective. |
| Did Defendants waive sovereign immunity by seeking a stay and promising to pay if affirmed? | Staying the reinstatement and assurances to pay amount to waiver. | No waiver; promises were conditional on affirmance, not a waiver. | Yes, waiver occurred; immunity not bar to post-stay payments. |
Key Cases Cited
- Ex parte Young, 209 U.S. 123 (1908) (injunctive relief against state officials to enforce federal law; not a suit against the State)
- Verizon Md., Inc. v. Pub. Serv. Comm’n, 535 U.S. 635 (2002) (prospective relief under Ex parte Young allowed; not require monetary relief against state treasury)
- Barnes v. Bosley, 828 F.2d 1258 (8th Cir. 1987) (backpay during stay treated as prospective relief under Eleventh Amendment)
- Coeur d’Alene Tribe v. Glenn, 521 U.S. 261 (1997) (Ex parte Young applies to federal statutes and state courts; federal rights vindicated)
- Edelman v. Jordan, 415 U.S. 651 (1974) (monetary relief payable out of state treasury not available; prospective relief allowed)
- Coleman v. Court of Appeals of Md., 132 S. Ct. 1327 (2012) (Congress failed to validly abrogate sovereign immunity; Ex parte Young may apply)
- Alden v. Maine, 527 U.S. 706 (1999) (sovereign immunity applies in state and federal court; exceptions apply)