Michael Wright v. State of Tennessee

Summary

The United States District Court for the Western District of Tennessee adopted a magistrate judge’s report and recommendation and granted Tennessee’s motion to dismiss Michael Wright’s challenge to the state marriage-license requirement. The court held that the Eleventh Amendment and sovereign immunity barred the claim against the State, and that the Ex parte Young exception did not apply because Wright sued no state official in an official capacity.

Holdings

1. A district court reviews de novo the findings or legal conclusions to which a party specifically objects and reviews the remainder of the report and recommendation for clear error.
2. The Eleventh Amendment barred Wright's suit against the State of Tennessee because Congress had not abrogated Tennessee's immunity for the § 1983 claim and Tennessee had not waived its immunity.
3. The Ex parte Young exception did not permit Wright's suit because he named no state official in an official capacity who was allegedly committing a continuing violation of federal law.

Questions Presented

1. Whether the district court properly reviewed the magistrate judge's report and recommendation under the de novo and clear-error standards applicable to specific and nonspecific objections.
2. Whether the Eleventh Amendment and state sovereign immunity barred Wright's 42 U.S.C. § 1983 suit against the State of Tennessee.
3. Whether the Ex parte Young exception to sovereign immunity permitted Wright's action.

Disposition

dismissed