Fitzpatrick v. Bitzer

E114956

United States Supreme Court case landmark sovereign immunity case

Fitzpatrick v. Bitzer is a 1976 U.S. Supreme Court decision holding that Congress may, under its Fourteenth Amendment enforcement powers, authorize private lawsuits for money damages against state governments despite Eleventh Amendment sovereign immunity.

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All labels observed (3)

Label	Occurrences
Fitzpatrick v. Bitzer canonical	3
Bitzer v. State of Connecticut, 519 F.2d 851 (2d Cir. 1975)	1
Fitzpatrick et al. v. Bitzer et al.	1

How this entity was disambiguated

This entity first appeared as the object of triple T969470 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.

NED1 Entity disambiguation (via context triple) gpt-5-mini-2025-08-07

Target entity: Fitzpatrick v. Bitzer
Context triple: [Eleventh Amendment to the United States Constitution, keyCase, Fitzpatrick v. Bitzer]

A. Bolling v. Sharpe
Bolling v. Sharpe is a 1954 U.S. Supreme Court case that held racial segregation in Washington, D.C. public schools unconstitutional under the Fifth Amendment’s Due Process Clause.
B. Printz v. United States
Printz v. United States is a 1997 U.S. Supreme Court decision that limited federal power by holding that Congress cannot compel state or local officials to implement federal regulatory programs.
C. Argersinger v. Hamlin
Argersinger v. Hamlin is a 1972 U.S. Supreme Court case that extended the right to counsel to defendants in misdemeanor cases that may result in imprisonment.
D. Briggs v. Elliott
Briggs v. Elliott was a landmark federal court case from South Carolina challenging racial segregation in public schools, and it became one of the key cases consolidated into Brown v. Board of Education.
E. Corrigan v. Buckley
Corrigan v. Buckley is a 1926 U.S. Supreme Court decision that upheld the enforceability of racially restrictive covenants in property deeds, paving the way for widespread legalized housing segregation until later overturned in effect by subsequent civil rights rulings.
F. None of above. chosen
G. Unsure - the case is ambiguous/there is not enough information to decide.

NED2 Entity disambiguation (via description) gpt-5-mini-2025-08-07

Target entity: Fitzpatrick v. Bitzer
Target entity description: Fitzpatrick v. Bitzer is a 1976 U.S. Supreme Court decision holding that Congress may, under its Fourteenth Amendment enforcement powers, authorize private lawsuits for money damages against state governments despite Eleventh Amendment sovereign immunity.

A. Bolling v. Sharpe
Bolling v. Sharpe is a 1954 U.S. Supreme Court case that held racial segregation in Washington, D.C. public schools unconstitutional under the Fifth Amendment’s Due Process Clause.
B. Printz v. United States
Printz v. United States is a 1997 U.S. Supreme Court decision that limited federal power by holding that Congress cannot compel state or local officials to implement federal regulatory programs.
C. Argersinger v. Hamlin
Argersinger v. Hamlin is a 1972 U.S. Supreme Court case that extended the right to counsel to defendants in misdemeanor cases that may result in imprisonment.
D. Briggs v. Elliott
Briggs v. Elliott was a landmark federal court case from South Carolina challenging racial segregation in public schools, and it became one of the key cases consolidated into Brown v. Board of Education.
E. Corrigan v. Buckley
Corrigan v. Buckley is a 1926 U.S. Supreme Court decision that upheld the enforceability of racially restrictive covenants in property deeds, paving the way for widespread legalized housing segregation until later overturned in effect by subsequent civil rights rulings.
F. None of above. chosen

Statements (47)

Predicate	Object
instanceOf	United States Supreme Court case ⓘ landmark sovereign immunity case ⓘ
areaOfLaw	civil rights ⓘ constitutional law ⓘ federal courts ⓘ
arguedDate	1976-03-29 ⓘ
causeOfAction	employment discrimination under Title VII ⓘ
citation	427 U.S. 445 ⓘ
concurrenceBy	John Paul Stevens ⓘ Lewis F. Powell Jr. ⓘ William J. Brennan Jr. ⓘ
country	United States ⓘ linked to: United States of America
court	Supreme Court of the United States ⓘ
decidedDate	1976-06-28 ⓘ
decisionDate	1976-06-28 ⓘ
docketNumber	75-251 ⓘ
fullCaseName	Fitzpatrick et al. v. Bitzer et al. ⓘ linked to: Fitzpatrick v. Bitzer
holding	Congress may, pursuant to its enforcement powers under Section 5 of the Fourteenth Amendment, authorize private suits for money damages against state governments ⓘ The Eleventh Amendment does not bar private suits for money damages against a state when Congress has validly abrogated state sovereign immunity under Section 5 of the Fourteenth Amendment ⓘ
involvedStatute	Equal Employment Opportunity Act of 1972 ⓘ Title VII of the Civil Rights Act of 1964 ⓘ
joinedByInMajority	Byron R. White ⓘ Lewis F. Powell Jr. ⓘ Potter Stewart ⓘ Thurgood Marshall ⓘ Warren E. Burger ⓘ William J. Brennan Jr. ⓘ
jurisdiction	federal question jurisdiction ⓘ
languageOfProceeding	English ⓘ
legalIssue	Congressional power under Section 5 of the Fourteenth Amendment ⓘ Eleventh Amendment sovereign immunity ⓘ linked to: Eleventh Amendment to the United States Constitution
majorityOpinionBy	William H. Rehnquist ⓘ
page	445 ⓘ
plaintiffs	male employees of the State of Connecticut ⓘ
priorHistory	Bitzer v. State of Connecticut, 519 F.2d 851 (2d Cir. 1975) ⓘ linked to: Fitzpatrick v. Bitzer
relatedConstitutionalProvision	Eleventh Amendment to the United States Constitution ⓘ Fourteenth Amendment to the United States Constitution ⓘ linked to: Fourteenth Amendment Section 5 of the Fourteenth Amendment ⓘ
remedySought	attorney’s fees ⓘ money damages ⓘ
reporter	United States Reports ⓘ
significance	recognized that the Civil War Amendments altered the federal-state balance regarding sovereign immunity ⓘ
stateParty	Connecticut ⓘ
subsequentCitation	cited as precedent in later Eleventh Amendment cases ⓘ
topic	abrogation of state sovereign immunity ⓘ state liability for employment discrimination ⓘ
volume	427 ⓘ

How these facts were elicited

Referenced by (5)

Full triples — surface form annotated when it differs from this entity's canonical label.

Eleventh Amendment to the United States Constitution → keyCase → Fitzpatrick v. Bitzer ⓘ

Hans v. Louisiana → isCitedBy → Fitzpatrick v. Bitzer ⓘ

Alden v. Maine → relatedCase → Fitzpatrick v. Bitzer ⓘ

Fitzpatrick v. Bitzer → fullCaseName → Fitzpatrick et al. v. Bitzer et al. ⓘ

linked to: Fitzpatrick v. Bitzer

Fitzpatrick v. Bitzer → priorHistory → Bitzer v. State of Connecticut, 519 F.2d 851 (2d Cir. 1975) ⓘ