Fitzpatrick v. Bitzer
United States Supreme Court
427 U.S. 445 (1976)
Congress amended Title VII in 1972 to let individuals sue state governments for money damages for employment discrimination. Fitzpatrick and other male state retirees (plaintiffs) sued Bitzer, Chairman of the Connecticut State Retirement Commission, and Connecticut itself (defendants) for gender-based discrimination in the state's retirement policies. The district court granted only injunctive relief, holding that monetary relief under the Title VII amendments would violate Connecticut's sovereign immunity under the Eleventh Amendment, and the court of appeals affirmed.
Whether Congress, pursuant to its power under § 5 of the Fourteenth Amendment, may authorize a private individual's suit for money damages against a state government without violating the state sovereignty protections of the Eleventh Amendment.