Are Georgia School Districts Immune from Federal Lawsuits?
A Georgia school district cannot claim immunity from federal lawsuits under the Eleventh Amendment to the U.S. Constitution, according to a federal circuit court in Atlanta. The court's decision finally addresses an issue that had gone unresolved for decades.
Zaneta Lightfoot taught English and drama at Woodland High School in Georgia's Henry County School District. Because she suffered from sickle cell anemia and occasionally experienced extreme pain, she applied for, and received, leave under the Family and Medical Leave Act. After a year of taking days off sporadically when she could not work, she received a disciplinary letter and a poor performance evaluation from the school. She sued the school district for violating the FMLA and other laws and was terminated the following year.
Initially, a federal district court dismissed her FMLA claim on the grounds that the school district was entitled to immunity under the Eleventh Amendment. The Eleventh Amendment generally protects states from federal lawsuits if the states have not consented to being sued under the circumstances involved. This immunity does not shield counties or cities, but it can protect state officials and entities acting as an "arm of the state." The 11th Circuit Court of Appeals had never ruled on whether this immunity protected Georgia schools from federal lawsuits.
Lightfoot appealed the dismissal of her case, and a panel of judges reversed the lower court's ruling, allowing the action to proceed. The reversal hinged on whether the school district was an "arm of the state." The Circuit Court panel said that it was, based on how state law defined the school district, the amount of state control over it, how it was funded, and who would be responsible for satisfying court judgments against it. The court rejected the school district's argument that, because school districts enjoy sovereign immunity, they are also entitled to immunity under the Eleventh Amendment.
The decision clears the way for a variety of federal employment law claims to be brought against Georgia school districts.
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