Will v. Michigan Department of State Police

1989-06-15

Headline: Ruling blocks money‑damage lawsuits against States and state officials by holding they are not “persons” under the federal civil‑rights law, limiting private damage claims against state governments and officials.

Holding: The Court held that neither a State nor a state official sued in an official capacity is a “person” under the federal civil‑rights statute, so plaintiffs cannot recover money damages from them under that law.

Real World Impact:

Bars money‑damage suits against States under the federal civil‑rights statute.
Prevents official‑capacity damage claims against state officers under that law.
Preserves injunctive relief against officials but limits damage remedies.

Topics: civil rights lawsuits, state sovereign immunity, government liability, official‑capacity claims

Summary

Background

Ray Will, a job applicant who says he was denied a promotion because of his brother’s activism, sued in Michigan courts under the federal civil‑rights law that lets people recover for constitutional violations. He named the Michigan Department of State Police and the State Police Director in the Director’s official role. Michigan courts split on whether a State or an official sued in an official capacity is a “person” under that law, and the case reached the U.S. Supreme Court to resolve the disagreement among lower courts.

Reasoning

The Court read the civil‑rights statute and historical materials and concluded the ordinary meaning of “person,” the Dictionary Act, and long‑standing sovereign‑immunity concerns do not show Congress unmistakably intended to make States liable under the statute. The majority relied on precedents about the Eleventh Amendment, the statutory history, and common‑law immunities to conclude that neither a State nor an official sued in an official capacity is a “person” for purposes of money damages under the law. The Court explained that suits for forward‑looking injunctions against officials remain treated differently.

Real world impact

As a result, plaintiffs cannot bring federal‑statute damage claims against a State or against state officers in their official capacity for money relief under that civil‑rights law, even when the suit is filed in state court. The decision affirms the Michigan court outcome and narrows who can be named as a defendant for money damages under the statute. The Court left intact the separate principle allowing prospective injunctive relief against officials.

Dissents or concurrances

Justices Brennan and Stevens dissented. They argued the statute’s language, the Dictionary Act, historical context, and earlier cases support treating States as “persons,” and they would have remanded questions about state consent or immunity for the state court to decide.