Fitzpatrick v. Bitzer 427 U.S. 445 (1976)

• Author: Theodore Eisenberg
• Pages: 1060

Page 1060

This case concerned Congress's power to modify states' ELEVENTH AMENDMENT immunity from suit in federal court. In the 1972 amendments to Title VII of the CIVIL RIGHTS ACT OF 1964, Congress extended Title VII to forbid employment discrimination by state employers. In Fitzpatrick, in an opinion by Justice WILLIAM H. REHNQUIST, the Court held that Congress, in exercising its FOURTEENTH AMENDMENT powers, and despite the Eleventh Amendment, could subject states to suit in federal courts for discriminatory behavior. Fitzpatrick was an important counterpoint to Employees v. Department of Public Health and Welfare (1973) and EDELMAN V. JORDAN (1974), cases that had held that other federal statutes were not meant to abrogate the states'...