Pennhurst State School And Hospital v. Halderman

465 U.S. 89 (1984)

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Nature of the Case

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Facts

Respondent- Halderman represented a class that had previously sued the Petitioner, Pennhurst School, and various Pennsylvania state officials in protest of the physical conditions of care at Pennhurst. The Respondent asserted various federal and state statutes as well as U.S. constitutional claims. The Circuit Court of Appeals decided in favor of the Respondents based exclusively on federal statutes embodied in the Developmentally Disabled Assistance and Bill of Rights Act, 42 U.S.C. §6010. This law provides right to habitation in the least restrictive means. The U.S. Supreme Court asserted that this statute asserted no such right and reversed this decision and remanded the case to the Circuit Court in order to apply an alternate constitutional provision or state law that did in fact accord such a right. However, on remand, the Circuit Court rejected Respondent-Halderman's claim and released its same decision unaltered. The Circuit Court claimed that the Eleventh Amendment barred litigation brought by private citizens against its home state. On the second appeal to the U.S. Supreme Court, the Court recognized that the Eleventh Amendment precluded Respondent-Halderman's action against the State and therefore, subject matter jurisdiction was lacking to adjudicate her claim. However, the Court remanded the case to the Circuit Court a second time to again determine if any alternate constitutional and statutory remedies were available under state law.