Supreme Court of the United States · 1991-11-05
Case and law context
Role: applied; posture: 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; claim:
Instances and excluded annotation blocks
| Case | Element | Holding and scope | Variant | Exact source quotations |
|---|---|---|---|---|
| /us/502/0021-01 — Supreme Court of the United States · 1991 | Personal involvement / causal connection ("subjects, or causes to be subjected") | not_reached Excluded from merits counts applied / merits | Unspecified variant | No source quotation recorded for this block. |
| /us/502/0021-01 — Supreme Court of the United States · 1991 | Action taken "under color of" state, territorial, or D.C. law | satisfied Counted merits instance applied / merits basis: pleaded Acts within lawful authority and "necessary to governmental functions" are still under color of law; no carve-out for authorized official acts. | public-official/exercise-of-official-authority | 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.Source: docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [2760:2967] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07.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.Source: docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [10623:10820] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07.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.Source: docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [9307:9471] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07. |
| /us/502/0021-01 — Supreme Court of the United States · 1991 | Damages remedy (legacy CASE id; not a prerequisite for prospective relief) | not_reached Excluded from merits counts applied / merits | Unspecified variant | No source quotation recorded for this block. |
| /us/502/0021-01 — Supreme Court of the United States · 1991 | Deprivation of a right, privilege, or immunity secured by the Constitution and laws | not_reached Excluded from merits counts applied / meritsUnderlying claims (patronage dismissal / First Amendment; due process) never examined; only whether the suit may proceed. | Unspecified variant | No source quotation recorded for this block. |
| /us/502/0021-01 — Supreme Court of the United States · 1991 | Suable "person" (natural person in individual capacity, official in official capacity for prospective relief, or municipality; excludes States) | satisfied Counted merits instance applied / merits basis: law; party: Hafer; count: damages claims; theory: personal-capacity suit; subject: party=Hafer; count=damages claims; theory=personal-capacity suit Personhood turns on the capacity in which the officer is SUED (who pays), not the capacity in which she ACTED; exercising official hire/fire authority does not convert a personal-capacity damages suit into a suit against the State. | individual/state-official-sued-in-personal-capacity-for-official-acts | Shortly after becoming auditor general, she dismissed 18 employees, including named respondent James Melo, Jr., on the basis that they “bought” their jobs.Source: docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [1031:1186] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07.These respondents allege that Hafer discharged them because of their Democratic political affiliation and support for her opponent in the 1988 election.Source: docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [1508:1660] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07.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.Source: docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [2469:2628] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07.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.Source: docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [7140:7341] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07.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.”Source: docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [7778:7984] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07.We hold that state officials, sued in their individual capacities, are “persons” within the meaning of § 1983.Source: docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [15867:15977] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07. |
| /us/502/0021-01 — Supreme Court of the United States · 1991 | Suable "person" (natural person in individual capacity, official in official capacity for prospective relief, or municipality; excludes States) | satisfied Excluded from merits counts applied / lower-court basis: law; party: Hafer; count: reinstatement claims; theory: official-capacity suit for prospective relief; subject: party=Hafer; count=reinstatement claims; theory=official-capacity suit for prospective relief Court of Appeals' holding, reported and endorsed by citation (Will n. 10) but not the question on certiorari. | official-capacity/state-official-sued-for-prospective-relief | They too filed suit against Hafer, seeking monetary damages and reinstatement under § 1983.Source: docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [1681:1772] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07.As to claims for reinstatement brought against Hafer in her official capacity, the court rested on our statement in Will that state officials sued for injunctive relief in their official capacities are “persons” subject to liability under § 1983.Source: docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [2191:2437] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07. |
| /us/502/0021-01 — Supreme Court of the United States · 1991 | Municipal policy or custom as moving force (Monell v. Department of Social Services) | not_reached Excluded from merits counts applied / meritsStated only as a contrast: personal-capacity plaintiffs need not show an entity policy or custom; official-capacity plaintiffs must. | Unspecified variant | No source quotation recorded for this block. |
| /us/502/0021-01 — Supreme Court of the United States · 1991 | Common-law absolute immunity (judicial, prosecutorial, legislative, witness functions) | not Counted merits instance applied / merits basis: law Qualified (personal) immunity remains available on remand and was not decided. | absolute-immunity/state-executive-employment-decision | State executive officials are not entitled to absolute immunity for their official actions.Source: docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [12127:12218] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07.officials seeking absolute immunity must show that such immunity is justified for the governmental function at issueSource: docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [11580:11696] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07.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.Source: docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [15978:16160] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07. |
| /us/502/0021-01 — Supreme Court of the United States · 1991 | Eleventh Amendment state sovereign immunity bar (official-capacity damages / retrospective relief) | not Counted merits instance applied / merits basis: law | sovereign-immunity/personal-capacity-damages-not-against-treasury | That is, the Eleventh Amendment does not erect a barrier against suits to impose “individual and personal liability” on state officials under § 1983.Source: docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [15323:15472] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07.Insofar as respondents seek damages against Hafer personally, the Eleventh Amendment does not restrict their ability to sue in federal court.Source: docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [15725:15866] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07. |
Court interpretations recorded from this case
interpretation
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.
/us/502/0021-01 — Supreme Court of the United States · 1991
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.Source:
docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [7140:7341] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07.Under Will v. Michigan Dept. of State Police (491 U.S. 58 (1989)), neither a State nor its officials acting in their official capacities are "persons" under § 1983 when sued for damages, though state officials sued in their official capacities for prospective injunctive relief (or in their personal capacities for damages under Hafer) are "persons".
interpretation
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.”
/us/502/0021-01 — Supreme Court of the United States · 1991
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.”Source:
docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [7778:7984] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07.Under Will v. Michigan Dept. of State Police (491 U.S. 58 (1989)), neither a State nor its officials acting in their official capacities are "persons" under § 1983 when sued for damages, though state officials sued in their official capacities for prospective injunctive relief (or in their personal capacities for damages under Hafer) are "persons".
interpretation
As to claims for reinstatement brought against Hafer in her official capacity, the court rested on our statement in Will that state officials sued for injunctive relief in their official capacities are “persons” subject to liability under § 1983.
/us/502/0021-01 — Supreme Court of the United States · 1991
As to claims for reinstatement brought against Hafer in her official capacity, the court rested on our statement in Will that state officials sued for injunctive relief in their official capacities are “persons” subject to liability under § 1983.Source:
docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [2191:2437] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07.Under Will v. Michigan Dept. of State Police (491 U.S. 58 (1989)), neither a State nor its officials acting in their official capacities are "persons" under § 1983 when sued for damages, though state officials sued in their official capacities for prospective injunctive relief (or in their personal capacities for damages under Hafer) are "persons".
interpretation
As to claims for reinstatement brought against Hafer in her official capacity, the court rested on our statement in Will that state officials sued for injunctive relief in their official capacities are “persons” subject to liability under § 1983.
/us/502/0021-01 — Supreme Court of the United States · 1991
As to claims for reinstatement brought against Hafer in her official capacity, the court rested on our statement in Will that state officials sued for injunctive relief in their official capacities are “persons” subject to liability under § 1983.Source:
docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [2191:2437] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07.Remedy-specific damages issue retained for CASE compatibility. Compensatory damages require proof of compensable loss; nominal damages and other remedies have distinct rules. Article III standing is separately represented by standing-injury and is not synonymous with a damages award.
interpretation
officials seeking absolute immunity must show that such immunity is justified for the governmental function at issue
/us/502/0021-01 — Supreme Court of the United States · 1991
officials seeking absolute immunity must show that such immunity is justified for the governmental function at issueSource:
docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [11580:11696] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07.Added by Pub. L. 104-317, § 309(c) (1996) to abrogate Pulliam v. Allen (466 U.S. 522 (1984)) with respect to injunctive relief against judges unless a declaratory decree was violated or unavailable.
interpretation
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.
/us/502/0021-01 — Supreme Court of the United States · 1991
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.Source:
docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [10623:10820] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07.Added by Pub. L. 96-170 (1979) to overturn District of Columbia v. Carter (409 U.S. 418 (1973)) and bring D.C. officials within § 1983.
interpretation
officials seeking absolute immunity must show that such immunity is justified for the governmental function at issue
/us/502/0021-01 — Supreme Court of the United States · 1991
officials seeking absolute immunity must show that such immunity is justified for the governmental function at issueSource:
docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [11580:11696] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07.Functional approach: absolute immunity attaches to judicial acts (Pierson v. Ray), prosecutorial advocacy intimately associated with the judicial phase (Imbler v. Pachtman), and legislative acts (Bogan v. Scott-Harris), but not administrative/investigative executive functions.
interpretation
State executive officials are not entitled to absolute immunity for their official actions.
/us/502/0021-01 — Supreme Court of the United States · 1991
State executive officials are not entitled to absolute immunity for their official actions.Source:
docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [12127:12218] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07.Functional approach: absolute immunity attaches to judicial acts (Pierson v. Ray), prosecutorial advocacy intimately associated with the judicial phase (Imbler v. Pachtman), and legislative acts (Bogan v. Scott-Harris), but not administrative/investigative executive functions.
interpretation
That is, the Eleventh Amendment does not erect a barrier against suits to impose “individual and personal liability” on state officials under § 1983.
/us/502/0021-01 — Supreme Court of the United States · 1991
That is, the Eleventh Amendment does not erect a barrier against suits to impose “individual and personal liability” on state officials under § 1983.Source:
docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [15323:15472] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07.Bars damages suits in federal court against a State or state officials in their official capacities (absent waiver, whereas § 1983 does not abrogate sovereign immunity under Quern v. Jordan, 440 U.S. 332 (1979)), but does not bar personal-capacity suits (Hafer) or Ex parte Young prospective injunctive relief.
interpretation
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.
/us/502/0021-01 — Supreme Court of the United States · 1991
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.Source:
docroot/ir/caselaw/us_502.jsonl#/us/502/0021-01; Unicode character offsets [10623:10820] (end exclusive); SHA-256 b981c1cb2a9bf4bab619f49a26674002633c907c86f39bd53f955befb5605c07.In Fourteenth Amendment claims, the statutory "under color of" state law requirement and the constitutional "state action" requirement converge.