Laborers’ International Union of North America, Local 860 v. Terease Z. Neff, Hon. Thomas F. O’Malley, and Cuyahoga County, Ohio Common Pleas Court, Juvenile Division

Summary

The Sixth Circuit affirmed dismissal of a labor union’s federal claims arising from the alleged breach of collective bargaining agreements with the Cuyahoga County Juvenile Court. The court held that the Juvenile Court is an arm of the State of Ohio entitled to sovereign immunity, that 42 U.S.C. § 1983 does not provide a cause of action for the union’s Contracts Clause claims, and that the Takings Clause claims failed because an adequate state-law contract remedy existed and qualified immunity applied to the damages claims. Chief Judge Sutton also issued a concurrence addressing the historical availability of § 1983 for Contracts Clause claims.

Holdings

1. The Cuyahoga County Juvenile Court is an arm of the State of Ohio for sovereign-immunity purposes, even though Cuyahoga County funds its day-to-day operations and would pay any judgment.
2. Under binding Sixth Circuit precedent, an alleged Contracts Clause violation cannot give rise to a cause of action under 42 U.S.C. § 1983.
3. The union could not obtain an injunction under the Takings Clause because Ohio provided an adequate legal remedy through a state-court contract or declaratory-judgment action.
4. The administrators were entitled to qualified immunity because no precedent clearly established that merely breaching a collective bargaining agreement under these circumstances violated the Takings Clause.

Questions Presented

1. Whether the Cuyahoga County Juvenile Court is an arm of the State of Ohio entitled to sovereign immunity.
2. Whether the union may pursue a Contracts Clause claim under 42 U.S.C. § 1983.
3. Whether the union was entitled to injunctive relief under the Takings Clause despite the availability of a state-law contract remedy.
4. Whether the administrators were entitled to qualified immunity from individual-capacity damages claims under the Takings Clause.

Disposition

affirmed