Virginia Office for Protection and Advocacy v. Stewart
131 S. Ct. 1632
| SCOTUS | 2011Background
- DD Act and PAIMI Act provide federal funds to states and require a protections and advocacy (P&A) system to protect rights of individuals with developmental disabilities and mental illness.
- P&A systems may be a state agency or private nonprofit, but must retain independence to avoid State interference.
- Virginia designated a state agency, VOPA, as its P&A system, with independent litigating authority and the power to sue state officials.
- VOPA opened an investigation into deaths and injuries at state mental hospitals and sought records from state officials; officials refused citing state-law privilege over peer-review materials.
- VOPA filed suit in federal court seeking a declaration of rights under DD/PAIMI Acts and an injunction to obtain records, invoking Ex parte Young to bypass Eleventh Amendment immunity.
- Court of Appeals held the action was not authorized by Ex parte Young as intrastate-state-agency litigation, prompting certiorari.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Ex parte Young permit a state agency to sue state officials in federal court for federal rights? | VOPA has a federal right against the State and may seek prospective relief. | Sovereign immunity bars intrastate suits between State actors in federal court. | Yes; Ex parte Young permits. |
| Does allowing intrastate agency suits undermine Virginia sovereignty? | No meaningful dignitary harm; agency action is permitted by Virginia law. | Such suits diminish the State’s dignity by adjudicating internal disputes in federal court. | No substantial sovereign-dignitary bar; permissible. |
| Is the novelty of an intrastate Ex parte Young suit a constitutional bar? | Novelty does not defeat a valid Young action where a federal right is involved. | Novel intrastate suits risk federal intrusion into state governance; caution is warranted. | Novelty does not defeat jurisdiction; principles support Young here. |
Key Cases Cited
- Ex parte Young, 209 U. S. 123 (1908) (establishes the narrow Young exception to sovereign immunity)
- Verizon Md. Inc. v. Public Serv. Comm’n of Md., 535 U. S. 635 (2002) (straightforward inquiry: ongoing federal-law violation and prospective relief)
- Coeur d’Alene Tribe v. Idaho, 521 U. S. 261 (1997) (limits Young where special sovereignty interests are implicated)
- Seminole Tribe of Fla. v. Florida, 517 U. S. 44 (1996) (determinative for whether detailed remedial schemes foreclose Young)
- Pennhurst State School & Hospital v. Halderman, 465 U. S. 89 (1984) (limits on applying Young to state-law violations and retroactivity)
- Alden v. Maine, 527 U. S. 706 (1999) (sovereign immunity preserved unless Congress or waiver applies)
- Edelman v. Jordan, 415 U. S. 651 (1974) (Young does not extend to retroactive relief)
- McKesson Corp. v. Division of Alcoholic Beverages and Tobacco, Fla. Dept. of Business Regulation, 496 U. S. 18 (1990) (context for state-sovereign considerations in jurisdiction)
- Printz v. United States, 521 U. S. 898 (1997) (limits on federal commandeering of state officers)
- Lehman Bros. v. Schein, 416 U. S. 386 (1974) (certification and abstention principles to avoid unnecessary federal intrusion)