Pennhurst State School & Hospital v. Halderman

Halderman and a class of plaintiffs sued Pennhurst State School and Hospital (defendant), a state institution for developmentally disabled patients, alleging inadequate care violating the Eighth and Fourteenth Amendments, the federal Developmentally Disabled Assistance and Bill of Rights Act (DD Act), and Pennsylvania's Mental Health and Mental Retardation Act of 1966 (MH/MR Act); the district court ruled for the plaintiffs and issued an injunction, and the Third Circuit affirmed. On a first trip to the Supreme Court, the Court found the DD Act created no substantive rights and remanded to determine whether state law, the Constitution, or the federal Rehabilitation Act could support the injunction; the Third Circuit found Pennsylvania's own MH/MR Act supported the remedial order and reaffirmed its judgment, prompting Pennhurst's renewed petition specifically challenging whether the Eleventh Amendment barred a federal court from enforcing state law against state officials this way.