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Phiffer v. Columbia River Correctional Institute

Citation: 63 F. App'x 335Docket: No. 01-35984; D.C. No. CV-01-01652-AJB

Court: Court of Appeals for the Ninth Circuit; April 21, 2003; Federal Appellate Court

Narrative Opinion Summary

The State appealed the district court's denial of its motion for judgment on the pleadings based on Eleventh Amendment sovereign immunity in a case involving Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act. The appellate court exercised jurisdiction over the interlocutory appeal and affirmed the district court's decision. It held that the State was not entitled to Eleventh Amendment immunity under Title II of the ADA, citing established case law, and reaffirmed that Congress had abrogated such immunity in this context. The court also ruled that the State waived its immunity under Section 504 by accepting federal funds, dismissing the State's reliance on certain Supreme Court rulings as unpersuasive. The decision was affirmed and remanded, and the court noted limitations on the decision's publication and citation, as per Ninth Circuit Rule 36-3.

Legal Issues Addressed

Abrogation of Sovereign Immunity by Congress

Application: The court reaffirmed its previous rulings that Congress has effectively abrogated sovereign immunity in the context of the ADA, despite the State's reliance on the Supreme Court's decision in Board of Trustees of the University of Alabama v. Garrett.

Reasoning: Furthermore, despite the State's arguments citing the Supreme Court's decision in Board of Trustees of the University of Alabama v. Garrett, the court reaffirms its previous rulings that Congress abrogated sovereign immunity in this context.

Eleventh Amendment Sovereign Immunity

Application: The court determined that the State is not entitled to sovereign immunity under the Eleventh Amendment in the context of Title II of the ADA.

Reasoning: The court affirms that the State is not entitled to Eleventh Amendment immunity under Title II of the Americans with Disabilities Act (ADA), referencing established cases that support this conclusion.

Jurisdiction over Interlocutory Appeals

Application: The court confirmed its jurisdiction to hear the interlocutory appeal concerning the denial of Eleventh Amendment immunity without requiring a 'serious and unsettled question of law.'

Reasoning: The court has jurisdiction over this interlocutory appeal, as established by precedent, and does not require a showing of a 'serious and unsettled question of law' for such appeals.

Precedential Limitations of the Decision

Application: The decision is not suitable for publication and cannot be cited in future cases, except where allowed by Ninth Circuit Rule 36-3.

Reasoning: The decision is affirmed and remanded, with a note that it is not suitable for publication and cannot be cited in future cases except as allowed by Ninth Circuit Rule 36-3.

Waiver of Eleventh Amendment Immunity under Section 504 of the Rehabilitation Act

Application: The court held that by accepting federal funds, the State waived its Eleventh Amendment immunity under Section 504 of the Rehabilitation Act, supported by several precedents.

Reasoning: Additionally, the court holds that the State waived its Eleventh Amendment immunity under Section 504 of the Rehabilitation Act by accepting federal funds, as supported by several precedents.