Howlett v. Rose

Howlett (plaintiff), a Florida student, sued a county school board and officials (defendants) under 42 U.S.C. § 1983 in Florida circuit court, alleging Fourth and Fourteenth Amendment violations. The court dismissed on the ground that Florida had not waived sovereign immunity for § 1983 suits against a school district, even though Florida circuit courts had previously heard § 1983 suits against individual officials, similar state-law claims against state defendants, and tort suits against school boards. Howlett petitioned the Supreme Court for certiorari.