FITZPATRICK V. BITZER 427 U.S. 445 (1976) CASE BRIEF

FITZPATRICK V. BITZER

427 U.S. 445 (1976)

NATURE OF THE CASE: This was a dispute over the power of Congress to authorize suits against State governments under section 5 of the 14th Amendment.

FACTS: Acting under 5 of the Fourteenth Amendment, Title VII authorized federal courts to award money damages in favor of a private individual against a state government found to have subjected that person to employment discrimination on the basis of 'race, color, religion, sex, or national origin.' Petitioners sued on behalf of all present and retired male employees of the State of Connecticut. alleging that certain provisions in the State's statutory retirement benefit plan discriminated against them because of their sex. The District Court held that the Connecticut State Employees Retirement Act violated Title VII's prohibition against sex-based employment discrimination. The District Court denied money damages as they were precluded by the Eleventh Amendment and by Edelman v. Jordan. The Court of agreed with the District Court that the action, 'insofar as it seeks damages, is in essence against the state and as such is subject to the Eleventh Amendment.' The Court of Appeals also found that, under the 1972 Amendments to Title VII, 'Congress intended to authorize a private suit for backpay by state employees against the state.' Notwithstanding this statutory authority, the Court of Appeals affirmed the District Court and held that, under Edelman, a 'private federal action for retroactive damages' is not a 'constitutionally permissible method of enforcing Fourteenth Amendment rights.' It reversed the District Court and remanded as to attorneys' fees, however, reasoning that such an award would have only an 'ancillary effect' on the state treasury of the kind permitted under Edelman.

ISSUE:

RULE OF LAW:

HOLDING AND DECISION:

LEGAL ANALYSIS:

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