Hafer v. Melo

502 U.S. 21 (1991) Supreme Court of the United States 1991-11-05

civil; discharged state employees sue state auditor general for damages and reinstatement; district court dismissed under Will; CA3 reversed; certiorari on whether state officers are personally liable for official acts; affirmed (result: remanded)

Facts

  1. 1 Suable "person" (natural person in individual capacity, official in official capacity for prospective relief, or municipality; excludes States) satisfied law
    Shortly after becoming auditor general, she dismissed 18 employees, including named respondent James Melo, Jr., on the basis that they “bought” their jobs.
  2. 1 Suable "person" (natural person in individual capacity, official in official capacity for prospective relief, or municipality; excludes States) satisfied law
    These respondents allege that Hafer discharged them because of their Democratic political affiliation and support for her opponent in the 1988 election.
  3. 1 Suable "person" (natural person in individual capacity, official in official capacity for prospective relief, or municipality; excludes States) satisfied law
    Turning to respondents’ monetary claims, the court found that six members of the Gurley group had expressly sought damages from Hafer in her personal capacity.
  4. 1 Suable "person" (natural person in individual capacity, official in official capacity for prospective relief, or municipality; excludes States) satisfied law
    the phrase “acting in their official capacities” is best understood as a reference to the capacity in which the state officer is sued, not the capacity in which the officer inflicts the alleged injury.
  5. 1 Suable "person" (natural person in individual capacity, official in official capacity for prospective relief, or municipality; excludes States) satisfied law
    By contrast, officers sued in their personal capacity come to court as individuals. A government official in the role of personal-capacity defendant thus fits comfortably within the statutory term “person.”
  6. 1 Suable "person" (natural person in individual capacity, official in official capacity for prospective relief, or municipality; excludes States) satisfied law
    We hold that state officials, sued in their individual capacities, are “persons” within the meaning of § 1983.
  7. 2 Action taken "under color of" state, territorial, or D.C. law satisfied pleaded
    While Hafer’s power to hire and fire derived from her position as auditor general, it said, a suit for damages based on the exercise of this authority could be brought against Hafer in her personal capacity.
  8. 2 Action taken "under color of" state, territorial, or D.C. law satisfied pleaded
    The requirement of action under color of state law means that Hafer may be liable for discharging respondents precisely because of her authority as auditor general.
  9. 2 Action taken "under color of" state, territorial, or D.C. law satisfied pleaded
    Because of that intent, we have held that in § 1983 actions the statutory requirement of action “under color of” state law is just as broad as the Fourteenth Amendment’s “state action” requirement.
  10. 15 Common-law absolute immunity (judicial, prosecutorial, legislative, witness functions) not law
    officials seeking absolute immunity must show that such immunity is justified for the governmental function at issue
  11. 15 Common-law absolute immunity (judicial, prosecutorial, legislative, witness functions) not law
    State executive officials are not entitled to absolute immunity for their official actions.
  12. 15 Common-law absolute immunity (judicial, prosecutorial, legislative, witness functions) not law
    The Eleventh Amendment does not bar such suits, nor are state officers absolutely immune from personal liability under § 1983 solely by virtue of the “official” nature of their acts.
  13. 16 Eleventh Amendment state sovereign immunity bar (official-capacity damages / retrospective relief) not law
    That is, the Eleventh Amendment does not erect a barrier against suits to impose “individual and personal liability” on state officials under § 1983.
  14. 16 Eleventh Amendment state sovereign immunity bar (official-capacity damages / retrospective relief) not law
    Insofar as respondents seek damages against Hafer personally, the Eleventh Amendment does not restrict their ability to sue in federal court.