928 F.3d 1209
10th Cir.2019Background
- Reginald Williams, a Utah inmate, sued UDOC, several prison officials (official-capacity), Zions Bank, and bank employees under 42 U.S.C. § 1983 alleging: UDOC withheld interest on inmate accounts (Fifth Amendment takings and due process) and prison officials retaliated against him for raising the issue (First Amendment).
- District court (with counsel appointed for Williams) dismissed most claims and defendants, leaving only a retaliation claim against five prison officials; it granted summary judgment for defendants on that claim.
- UDOC and the prison-official defendants asserted Eleventh Amendment immunity as an arm of the State of Utah; the district court did not rule on that immunity ground below.
- On appeal, the Tenth Circuit considered Eleventh Amendment immunity sua sponte, concluded UDOC and the official-capacity defendants are immune, and held the Takings Clause claim is barred in federal court when state courts are available to hear the claim.
- The court rejected Williams’s attempt to treat the remaining claims as personal-capacity suits (he did not identify individual acts by each official) and found no viable Ex parte Young request for prospective relief against the named Executive Director.
- The Tenth Circuit affirmed the judgment for defendants but remanded with instructions to dismiss Williams’s claims against the UDOC Defendants without prejudice (Eleventh Amendment dismissal).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Eleventh Amendment bars Williams’s Fifth Amendment takings claim against UDOC and officials sued in their official capacities | Williams argued Eleventh Amendment does not bar a federal takings claim (cites Lucas) | UDOC argued it is an arm of the state and thus immune from federal suit | Held: Eleventh Amendment bars the federal takings claim because Utah courts are available; dismissal without prejudice |
| Whether Ex parte Young permits prospective injunctive relief against UDOC Executive Director (Haddon) | Williams contended injunctive relief against Haddon is available | Defendants said Ex parte Young applies only to individual officers and complaint did not allege ongoing violation by a named official | Held: No viable Ex parte Young claim; complaint did not allege an ongoing violation by Haddon requiring prospective relief |
| Whether retaliation claim can proceed for monetary relief against officials in official capacity | Williams maintained retaliation occurred (seized papers, negative parole report) | Defendants invoked Eleventh Amendment immunity for official-capacity damages | Held: Monetary damages barred by Eleventh Amendment; plaintiff did not press prospective relief on appeal |
| Whether Williams pursued personal-capacity claims against individual prison officials | Williams used collective references to defendants and did not specify individual acts | Defendants argued lack of particularized allegations prevents personal-capacity liability | Held: Williams did not adequately plead personal-capacity claims; court declined to treat collective allegations as sufficient |
Key Cases Cited
- Edelman v. Jordan, 415 U.S. 651 (recognizing Eleventh Amendment bars federal suits against nonconsenting states)
- Lucas v. S. Carolina Coastal Council, 505 U.S. 1003 (framework for Fifth Amendment takings claims)
- Knick v. Twp. of Scott, 588 U.S. _ (2019) (landowner may bring federal takings claim without first suing in state court)
- Ex parte Young, 209 U.S. 123 (1908) (prospective injunctive relief against state officers to enjoin ongoing federal-law violations)
- Colby v. Herrick, 849 F.3d 1273 (10th Cir.) (Eleventh Amendment may be considered sua sponte; dismissal on Eleventh Amendment is without prejudice)
- Peterson v. Martinez, 707 F.3d 1197 (10th Cir.) (Eleventh Amendment extends to arms of the state and official-capacity suits)
- Hutto v. S.C. Ret. Sys., 773 F.3d 536 (4th Cir.) (Fifth Amendment takings claims against states barred in federal court when state courts available)
- Jachetta v. United States, 653 F.3d 898 (9th Cir.) (Eleventh Amendment bars federal takings claims against states if state courts can adjudicate them)