Burks v. Retirement Systems of Alabama

Summary

The Alabama Supreme Court reviews by mandamus the denial of a motion to dismiss claims challenging a PEEHIP policy that reduced health-insurance allotments for public-school educators married to one another and raising dependent children. The court holds that sovereign immunity bars the state-law claims and monetary claims against the relevant state officials and entities, while prospective federal injunctive-relief claims under 42 U.S.C. § 1983 may proceed against specified officials.

Holdings

1. The plaintiffs’ state-law claims were barred by Article I, § 14 of the Alabama Constitution because they did not fall within a recognized exception to state sovereign immunity.
2. The Eleventh Amendment barred the plaintiffs’ claims for restitution and other monetary relief under § 1983 against the PEEHIP Board members and Bronner in their official capacities.
3. The Eleventh Amendment did not bar the plaintiffs’ claims for prospective injunctive relief against the PEEHIP Board members and Bronner in his capacity as secretary-treasurer of PEEHIP.
4. The circuit court was directed to dismiss all claims against RSA, PEEHIP, PEEHIF, TRS, the PEEHIP Board, the TRS Board, the members of the TRS Board, and Bronner in his capacities as chief executive officer of RSA and secretary-treasurer of TRS.

Questions Presented

1. Whether the public-education plaintiffs’ state-law claims against the PEEHIP entities, board members, and officials in their official capacities were barred by Article I, § 14 of the Alabama Constitution.
2. Whether the plaintiffs’ requests for declaratory, injunctive, restitutionary, costs, and attorney-fee relief fell within an exception to Alabama sovereign immunity.
3. Whether the Eleventh Amendment barred the plaintiffs’ claims for monetary relief under 42 U.S.C. § 1983 against PEEHIP officials sued in their official capacities.
4. Whether the Eleventh Amendment permitted the plaintiffs’ claims for prospective injunctive relief under 42 U.S.C. § 1983 against those officials.
5. Whether the claims against the RSA, PEEHIP, PEEHIF, TRS, the respective boards, the TRS board members, and Bronner in specified capacities should be dismissed based on the plaintiffs’ stated agreement to dismiss them.

Disposition

writ_granted