Edelman v. Jordan
Edelman v. Jordan is a significant United States Supreme Court case that addressed the issue of state immunity under the Eleventh Amendment. The case arose when John Jordan sued the state of Illinois, claiming that the state was violating the Fourteenth Amendment by delaying retroactive payments of benefits mandated by federal law. Initially, a federal district court ruled in favor of the beneficiaries, but this decision was appealed and ultimately reversed by the Supreme Court, which held a 5-4 majority. The Court, led by Justice William H. Rehnquist, determined that Illinois had not waived its Eleventh Amendment rights by participating in a federal program, and that the Eleventh Amendment generally protects states from lawsuits in federal court without their consent. The ruling clarified that while states can be enjoined in future policy matters, they cannot be sued for retroactive payments. Dissenting opinions from Justices Douglas, Brennan, and Marshall highlighted concerns with the majority's interpretation, and subsequent legal decisions have since modified the implications of the Edelman ruling. This case remains a pivotal point of reference in discussions surrounding state sovereignty and federal judicial authority.
Edelman v. Jordan
Date: March 25, 1974
Citation: 415 U.S. 651
Issue: Eleventh Amendment
Significance: This Supreme Court decision, reached by a conservative majority, protected states from class-action suits by citizens alleging that these states were undermining federal legislation by granting them benefits too late.
John Jordan sued Illinois by suing various of its state and county officials, asserting they were paying out benefits later than federal law mandated and therefore violating the Fourteenth Amendment rights of the beneficiaries. A federal district court agreed and ordered retroactive payments to the class-action beneficiaries. Illinois appealed and lost in the court of appeals. However, the Supreme Court ruled in favor of Illinois. In the 5-4 majority decision written by Justice William H. Rehnquist, the Court ruled that Illinois did not waive its Eleventh Amendment rights by participating in the federal program and that the Eleventh Amendment prohibited within limits federal court lawsuits against a state without the state’s consent brought by citizens of that state or of other states. The Court reasoned that although Ex parte Young (1908) allowed injunctions against states in matters affecting future policies, it did not permit suits for retroactive payments.
Justices William O. Douglas, William J. Brennan, Jr., and Thurgood Marshall wrote separate dissents, and Justice Harry A. Blackmun joined Marshall. These dissenting justices opposed the majority holdings on more than one front. Later decisions limited the impact of Edelman and allowed Congress to circumvent this state immunity issue.