Hess v. Port Authority Trans-Hudson Corporation
Headline: Ruling allows injured railroad workers to sue the Port Authority’s PATH in federal court, rejecting state-style Eleventh Amendment immunity and letting federal FELA claims proceed.
Holding: The Court held that PATH, the Port Authority’s bistate railroad, is not entitled to Eleventh Amendment immunity and may be sued in federal court on federal FELA claims.
- Allows injured railroad workers to pursue FELA claims against PATH in federal court.
- Prevents Port Authority from invoking Eleventh Amendment immunity for these federal claims.
- Stops state 1-year consent limits from barring timely federal FELA suits.
Summary
Background
Albert Hess and Charles Walsh were railroad workers injured while working for PATH, a commuter railroad wholly owned by the Port Authority of New York and New Jersey. They sued in federal court under the Federal Employers' Liability Act (FELA). The district court and the Third Circuit dismissed their suits, concluding PATH could claim Eleventh Amendment immunity as if it were a State and that the States' one-year consent-to-sue limit barred the cases.
Reasoning
The Court addressed whether PATH, a bistate entity created by compact with Congress’ consent, can invoke Eleventh Amendment protection from federal suits. The Justices emphasized the Amendment’s concern with protecting state treasuries and dignity. Because the Port Authority and PATH generate their own revenues, pay their own debts, and the States are not legally liable for their judgments, the Court found no real threat to the States’ treasuries or dignity. The Court therefore rejected PATH’s claim to Eleventh Amendment immunity and reversed the Third Circuit.
Real world impact
Practically, injured workers asserting federal FELA rights can press those claims in federal court against PATH rather than be barred by the States’ shorter one-year consent period. The decision resolves an existing split among appeals courts about whether compact-created agencies get state immunity. The case was sent back to lower courts for further proceedings on the merits of the workers’ federal claims.
Dissents or concurrances
Justice Stevens joined and added a critique of broad Eleventh Amendment doctrines. Justice O’Connor dissented, arguing the Port Authority’s state-appointed governance and oversight support treating it like a State arm and preserving Eleventh Amendment immunity.
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