Meyers Et Al. v. Pennsylvania Et Al.
Headline: Bus crash victims’ federal lawsuit against Pennsylvania blocked as Court denies review, leaving lower-court dismissal in place and preventing damages claims under federal highway safety regulations.
Holding: The Supreme Court denied the petition for review, leaving the lower courts’ dismissal in place and preventing the plaintiffs from pursuing damages in federal court under the federal highway regulations and Eleventh Amendment ruling.
- Leaves plaintiffs’ federal damages claims dismissed for now.
- States may remain shielded from federal-damage suits by Eleventh Amendment.
- Federal remedy limited to withholding or terminating highway funds.
Summary
Background
A group of young people were traveling by bus when it skidded on wet pavement, rotated 180 degrees, went through a guardrail, and fell down an embankment, killing seven children. The National Transportation Safety Board reported low skid resistance and an ineffective guardrail. The plaintiffs sued the State of Pennsylvania in federal court, claiming the State failed to follow federal highway safety regulations it accepted when it took federal funds.
Reasoning
The core question was whether private individuals can sue a State for money damages for allegedly violating federal highway safety rules. The District Court dismissed the suit, and the Court of Appeals affirmed, finding no private right to sue under the federal statutes and holding the State immune from suit in federal court under the Eleventh Amendment. The lower courts also noted the statutory remedy is administrative withdrawal or withholding of federal funds.
Real world impact
Because the Supreme Court denied review, the lower-court dismissal remains in place and the plaintiffs cannot pursue these federal damages claims now. The opinions point to administrative enforcement—such as withholding federal highway funds—as the explicit statutory remedy. The denial leaves the broader legal question about private suits against States under these highway statutes unresolved at the Supreme Court level.
Dissents or concurrances
Justice Douglas dissented from the denial of review, arguing that by accepting federal highway funds and by state law requiring cooperation, Pennsylvania waived its immunity and that a private right to sue should be allowed; Justices Brennan and Marshall would have granted review.
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