Pennhurst State School and Hospital v. Halderman

Not to be confused with Pennhurst State Sch. & Hosp. v. Halderman, 451 U.S. 1 (1981).

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1984 United States Supreme Court case

Pennhurst State School and Hospital v. Halderman
Supreme Court of the United States
Argued February 22, 1983 Reargued October 3, 1983 Decided January 23, 1984
Full case name	Pennhurst State School and Hospital v. Halderman
Docket no.	81-2101
Citations	465 U.S. 89 (more)104 S. Ct. 900; 79 L. Ed. 2d 67
Argument	Oral argument
Reargument	Reargument
Court membership
Chief Justice Warren E. Burger Associate Justices William J. Brennan Jr. · Byron White Thurgood Marshall · Harry Blackmun Lewis F. Powell Jr. · William Rehnquist John P. Stevens · Sandra Day O'Connor
Case opinions
Majority	Powell, joined by Burger, White, Rehnquist, O'Connor
Dissent	Stevens, joined by Brennan, Marshall, Blackmun
Dissent	Brennan
Laws applied
U.S. Const. amend. XI; Developmentally Disabled Assistance and Bill of Rights Act of 1975

Pennhurst State School and Hospital v. Halderman, 465 U.S. 89 (1984), was a United States Supreme Court decision holding that the Eleventh Amendment prohibits a federal court from ordering state officials to obey state law.

Background

The lawsuit was a federal class action, asserting that those with developmental disabilities in the care of the state have a constitutional right to appropriate care and education. Terri Lee Halderman had been a resident of Pennhurst State School and Hospital, and following multiple episodes of abuse, she and her family filed suit in the federal district court. The suit started after Halderman had visited her parents at home and was found to have unexplained bruises. Although the case was not expected to reach the level it did, the courts later found that conditions at Pennhurst were unsanitary, inhumane and dangerous, violating the Fourteenth Amendment, and that Pennhurst used cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments, as well as the Pennsylvania Mental Health and Retardation Act of 1966 (MH/MR). The District Court ruled that certain of the patients' rights had been violated. The District Court decision was the first time that any federal court ruled that an institution must be closed based on a constitutional right to community services.

A panel discussion: five people sitting at a long table facing an audience out of frame and the moderator, Janet Albert-Herman, standing at a podium. The room is slightly dark and woody. A screen with captioning is behind the panel. — Panel discussion, "The Disability Rights Movement: From Pennhurst Until Today", U.S. Capitol Visitor Center, Washington, D.C., 27 June 2016. Left to right: James W. Conroy, principal investigator on the *Pennhurst Longitudinal Study* and co-president of the Pennhurst Memorial and Preservation Alliance; Nancy Thaler, Deputy Secretary, Pennsylvania Department of Human Services; Peter Berns, chief executive officer, the Arc of the United States; Jean Searle, member of the Pennhurst class and co-president of the Pennhurst Memorial and Preservation Alliance; Thomas Gilhool, Public Interest Law Center of Philadelphia and lead plaintiff's attorney in Penshurst v. Halderman; Janet Albert-Herman, a board member of the Arc of Pennsylvania and Treasurer of the Pennhurst Memorial and Preservation Alliance.

References

Pennhurst State School and Hospital v. Halderman, 465 U.S. 89 (1984).
Halderman v. Pennhurst State School & Hospital, 446 F. Supp. 1295 (E.D. Pa. 1978).
U.S. District Court, e.D., Pennsylvania. (1977). "Halderman v. Pennhurst State School and Hospital. 23 Dec 1977". Federal Supplement. 446: 1295–329. PMID 11646079.
"Pennsylvania Mental Health and Retardation Act of 1966" (PDF). Temple University. Commonwealth of Pennsylvania. Archived from the original (PDF) on November 27, 2014. Retrieved January 17, 2016.
Scott, P.M.; Ferleger, D. (1983). "Rights and dignity: Congress, the Supreme Court, and people with disabilities after Pennhurst". Western New England Law Review. 5 (3): 327–61. PMID 11658602.
Anti-Institutionalization and the Supreme Court, 14 Rutgers L.Rev. 595 (1983).

Bibliography

Court documents

Law journal analyses

Boyd, Penelope A. (1981). "The Aftermath of the DD Act: Is there Life after Pennhurst?". University of Arkansas at Little Rock Law Journal. 4 (3). University of Arkansas at Little Rock, Bowen School of Law: 448–466.
Brant, Jonathan (1983). "Pennhurst, Romeo, and Rogers: The Burger Court and Mental Health Law Reform Litigation". The Journal of Legal Medicine. 4 (3): 323–348. doi:10.1080/01947648309513387. PMID 6605401.
Brant, Jonathan (1983). "The Hostility of the Burger Court to Mental Health Law Reform Litigation". Bulletin of the American Academy of Psychiatry and the Law. 11 (1): 77–90. PMID 6850110.
Chemerinsky, Erwin (Summer 1985). "State Sovereignty and Federal Court Power: The Eleventh Amendment after Pennhurst v. Halderman" (PDF). Hastings Constitutional Law Quarterly. 12 (4). University of California, Hastings College of the Law: 643–668. Archived from the original (PDF) on October 16, 2015. Retrieved June 22, 2016.
Ferleger, David; Boyd, Penelope A. (April 1979). "Anti-Institutionalization: The Promise of the Pennhurst Case". Stanford Law Review. 31 (4). Stanford Law School: 717–752. doi:10.2307/1228423. JSTOR 1228423. PMID 10242374.
Ferleger, David; Scott, Patrice Maguire (1983). "Rights and Dignity: Congress, the Supreme Court, and People with Disabilities after Pennhurst". Western New England Law Review. 5 (3). Western New England University School of Law: 327–361. PMID 11658602.
Smith, Peter J. (May 2001). "Penshurst, Chevron, and the Spending Power". Yale Law Journal. 110 (7). The Yale Law Journal Company, Inc.: 1, 187–1, 245. doi:10.2307/797527. JSTOR 797527. S2CID 53607082.

Journalism

"Pennsylvania Settles Key Suit on Facilities for the Retarded". New York Times. July 15, 1984. Retrieved November 1, 2016.
Levey, Noam N. (February 25, 2015). "The Conservative Ruling that Might Save Obamacare". Los Angeles Times. Los Angeles, Cal. Retrieved June 20, 2016.
McIntyre, Adrianna (March 3, 2015). "Understanding 'Pennhurst': The Legal Doctrine that Could Save Obamacare". VOX. Retrieved June 20, 2016.

Other sources

Conroy, James W.; Bradley, Valerie (March 1, 1985). The Pennhurst Longitudinal Study: A Report of Five Years Research and Analysis (Report). Philadelphia, Penn.: Temple University Developmental Disabilities Center. Retrieved November 1, 2016.

External links

Text of Pennhurst State School and Hospital v. Halderman, 465 U.S. 89 (1984) is available from: CourtListener Justia Library of Congress Oyez (oral argument audio)
Suffer The Little Children, a 1968 exposé on Pennhurst State School by NBC10 reporter Bill Baldini.

United States Eleventh Amendment case law

General

Hollingsworth v. Virginia (1798)
Osborn v. Bank of the United States (1824)
Ex parte Madrazzo (1833)
Hans v. Louisiana (1890)
Giles v. Harris (1903)
Ex parte Young (1908)
Murray v. Wilson Distilling Co. (1909)
Edelman v. Jordan (1974)
Scheuer v. Rhodes (1974)
Quern v. Jordan (1979)
Nevada v. Hall (1979)
Pennhurst State School and Hospital v. Halderman (1984)
County of Oneida v. Oneida Indian Nation of New York State (1985)
Welch v. Texas Dept. of Highways and Public Transp. (1987)
Blatchford v. Native Village of Noatak (1991)
Idaho v. Coeur d'Alene Tribe of Idaho (1997)
Lapides v. Board of Regents of University System of Georgia (2002)
Northern Insurance Co. of New York v. Chatham County (2006)
Franchise Tax Board of California v. Hyatt II (2016)
Franchise Tax Board of California v. Hyatt III (2019)

Abrogation

Under Article I

Parden v. Terminal R. Co. of Ala. Docks Dept. (1964)
Employees v. Missouri Public Health Dept. (1973)
Atascadero State Hospital v. Scanlon (1985)
Pennsylvania v. Union Gas Co. (1989)
Seminole Tribe of Florida v. Florida (1996)
Florida Prepaid Postsecondary Education Expense Board v. College Savings Bank (1999)
College Savings Bank v. Florida Prepaid Postsecondary Education Expense Board (1999)
Alden v. Maine (1999)
Federal Maritime Commission v. South Carolina State Ports Authority (2002)
Central Virginia Community College v. Katz (2006)
Allen v. Cooper (2020)
PennEast Pipeline Co. v. New Jersey (2021)
Torres v. Texas Department of Public Safety (2022)
Financial Oversight and Management Board for Puerto Rico v. Centro de Periodismo Investigativo, Inc. (2023)

Under the 14th Amendment

Katzenbach v. Morgan (1966)
Fitzpatrick v. Bitzer (1976)
Dellmuth v. Muth (1989)
City of Boerne v. Flores (1997)
Florida Prepaid Postsecondary Education Expense Board v. College Savings Bank (1999)
Kimel v. Florida Board of Regents (2000)
United States v. Morrison (2000)
Board of Trustees of the University of Alabama v. Garrett (2001)
Nevada Department of Human Resources v. Hibbs (2003)
Tennessee v. Lane (2004)
United States v. Georgia (2006)
Coleman v. Court of Appeals of Maryland (2012)

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