Will V. Michigan Department of State Police - Court's Decision

Court's Decision

In a 5 to 4 decision delivered by Justice White, the U.S. Supreme Court held that neither States nor state officials acting in their official capacities are "persons" within the meaning of 42 U.S.C. § 1983 when being sued for monetary damages. The Court found that § 1983 would not provide a federal forum for litigants who were seeking a remedy against a State for alleged deprivations of civil liberties because the Eleventh Amendment barred such suits unless the State has waived its sovereign immunity or unless Congress has exercised its power under § 5 of the Fourteenth Amendment to override that immunity. The majority found that even though state officials literally are persons, suits brought against them in their official capacity were not really suits against the officials, but were rather suits against the officials' offices, no different from a suit against the State itself. This ruling came despite the fact that the Court had previously ruled that a state official acting in an official capacity, when sued for injunctive relief, would be a person under §1983 because "official-capacity actions for prospective relief are not treated as actions against the State."