Edelman v. Jordan
| Edelman v. Jordan | |
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| Argued December 12, 1973 Decided March 25, 1974 |
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| Full case name | Joel Edelman, Director, Department of Public Aid of Illinois v. John Jordan |
| Citations | 415 U.S. 651 (more)
94 S. Ct. 1347; 39 L. Ed. 2d 662; 1974 U.S. LEXIS 115
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| Prior history | Certiorari to the United States Court of Appeals for the Seventh Circuit |
| Holding | |
| Because of the sovereign immunity recognized in the Eleventh Amendment, a federal court could not order a State to pay back funds unconstitutionally withheld from parties to whom they were due. | |
| Court membership | |
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| Case opinions | |
| Majority | Rehnquist, joined by Burger, Stewart, White, Powell |
| Dissent | Douglas |
| Dissent | Brennan |
| Dissent | Marshall, joined by Blackmun |
| Laws applied | |
| U.S. Const. amend. XI | |
Edelman v. Jordan, 415 U.S. 651 (1974), was a United States Supreme Court case that held that, because of the sovereign immunity recognized in the Eleventh Amendment, a federal court could not order a State to pay back funds unconstitutionally withheld from parties to whom they were due.
The Plaintiff, John Jordan, in a class action suit, sued Illinois officials who administered federal-state of Aid to the Aged, Blind, or Disabled (AABD). Jordan alleged that the program monies had been administered in a way that violated both federal laws and the Fourteenth Amendment to the U.S. Constitution. Specifically, Jordan claimed that the Illinois administrators were applying their own guidelines which ignored federally mandated time limits, thereby not getting aid to applicants fast enough. The federal law required that applicants who qualify receive aid within 30 or 45 days, depending on their condition, but the Illinois agency was taking up to four months to disburse aid - and when such aid was distributed, it was not paid retroactively to the time when the state should have started paying it according to the federal guidelines.
Jordan sought relief including a positive injunction to require the State to award him and others in his position the aid that they had missed because of the lateness in processing the applications. The United States District Court found the Illinois guidelines to be inconsistent with the federal statute, and ordered Illinois to follow the federal guidelines, and to release to the aid applicants all funds "wrongfully withheld". The United States Court of Appeals for the Seventh Circuit affirmed, and the case was taken to the Supreme Court, with agency director Joel Edelmen named as the party representing the state of Illinois.
Since the 1890 decision in Hans v. Louisiana, the Eleventh Amendment had been held to recognize the sovereign immunity of states from suits by their citizens. However, the 1908 case of Ex parte Young had allowed an exception, that citizens could seek injunctive relief against state officials to stop them from carrying out unconstitutional state policies.
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