Kimel v. Florida Board of Regents

2000-01-12

Headline: Age-discrimination money claims against state employers blocked: Justices find ADEA signals suits against States but say Congress exceeded its Fourteenth Amendment power, stopping individuals from getting federal money damages from state employers.

Holding: The Court held that although Congress clearly intended the ADEA to allow suits against States, Congress exceeded its Section 5 Fourteenth Amendment enforcement power, so private money-damage suits against States under the ADEA are barred in federal court.

Real World Impact:

Bars federal money-damage suits by state employees under the ADEA.
State workers must use state anti-discrimination laws or other state remedies.
Federal courts cannot award ADEA damages against Alabama and Florida state employers.

Topics: age discrimination, state immunity from suit, employment lawsuits, federal vs state power

Summary

Background

Three groups of older employees sued their state employers — university professors in Alabama and Florida and a Florida corrections employee — claiming age discrimination and seeking money damages under the Age Discrimination in Employment Act (ADEA). The state employers moved to dismiss, arguing they were immune from suit under the Eleventh Amendment. The appeals were consolidated after lower courts split and the federal courts of appeals disagreed about whether the ADEA validly allowed suits against States.

Reasoning

The Court first asked whether Congress clearly intended the ADEA to let individuals sue States, and then whether Congress had the constitutional power to do so. The majority concluded that Congress did speak clearly by incorporating enforcement provisions that mention public agencies. But applying the Fourteenth Amendment enforcement standard (the Court’s “congruence and proportionality” test), the Justices held that Congress exceeded its Section 5 power. The Court explained that constitutional equal-protection law treats age classifications under a lenient (rational) standard, previous cases did not show states were committing widespread unconstitutional age discrimination, and the ADEA prohibits a much broader set of state employment choices than the Constitution would.

Real world impact

Because the Court found Congress lacked authority to subject States to ADEA money damages suits, the federal suits were barred and must be dismissed. State employees who face age discrimination cannot get ADEA money damages from their state employers in federal court and must rely on state anti-discrimination laws or other state remedies. The Court affirmed the lower court judgment dismissing the consolidated cases.

Dissents or concurrances

Justice Stevens (joined by three Justices) disagreed in part, arguing Congress can enforce workplace rules against public employers and allow private suits; Justice Thomas (joined by Justice Kennedy) dissented in part, arguing the ADEA did not unmistakably show Congress’ intent to abrogate state immunity.