Frew v. Hawkins
Texas parents filed a class action lawsuit on behalf of their children against state healthcare officials, claiming deficiencies in the state's Medicaid program. The case was settled through a consent decree, a written agreement similar to a contract that the court approves and has the power to enforce. Two and a half years later, parents were unsatisfied with the state's progress and filed a motion to enforce the consent decree. The district court found that the consent decree was enforceable, but the court of appeals reversed, holding that the state was immune from enforcement under the Eleventh Amendment, which provides that a state cannot be sued by individuals from other states, countries, or its own residents unless it explicitly waives immunity. The court of appeals held that a consent decree is not enforceable against a state or its officials except to vindicate a federal right under 42 U.S.C. § 1983. The court found no violation of a federal right and no waiver of sovereign immunity; therefore, the consent decree was unenforceable.
Questions Presented:
1. Do state officials waive 11th Amendment immunity by urging the district court to adopt a consent decree when the decree is based on federal law and specifically provides for the district court's
ongoing supervision of the officials' decree compliance?
2. Does the 11th Amendment bar a district court from enforcing a consent decree entered into by state officials unless the plaintiffs show that the "decree violation is also a violation of a
federal right" under 42 U.S.C. § 1983?
