Coleman v. Court of Appeals of Maryland: Supreme Court Rules that Sovereign Immunity Bars FMLA Action v. State

A quick note about this case.  In Coleman v. Court of Appeals of Maryland, 132 S.Ct. 1327 (3/20/12), the Supreme Court of the United States held that a state's sovereign immunity bars a state employee from suing for damages under federal law, in this case the Family and Medical Leave Act of 1993.  

The question in this case is whether a state employee is allowed to recover damages from the state entity that employs him by invoking one of the provisions of a federal statute that, in express terms, seeks to abrogate the States' immunity from suits for damages. The statute in question is the Family and Medical Leave Act of 1993, 107 Stat. 6, 29 U.S.C. § 2601 et seq. The provision at issue requires employers, including state employers, to grant unpaid leave for self care for a serious medical condition, provided other statutory requisites are met, particularly requirements that the total amount of annual leave taken under all the Act's provisions does not exceed a stated maximum. § 2612(a)(1)(d). In agreement with every Court of Appeals to have addressed this question, this Court now holds that suits against States under this provision are barred by the States' immunity as sovereigns in our federal system. 

Id. at 1332.  The opinion is available here.