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Kimel v. Florida Board of Regents
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| Kimel v. Florida Board of Regents | |
| Reference: 528 U.S. 62 | |
| Term: 2000 | |
| Important Dates | |
| Argued: October 13, 1999 Decided: January 11, 2000 | |
| Outcome | |
| United States Court of Appeals for the Eleventh Circuit affirmed | |
| Majority | |
| Sandra Day O'Connor • William Rehnquist • Antonin Scalia • Anthony Kennedy • Clarence Thomas | |
| Dissenting | |
| John Paul Stevens • David Souter • Ruth Bader Ginsburg • Stephen Breyer | |
Kimel v. Florida Board of Regents is a case decided on January 11, 2000, by the United States Supreme Court holding that states can discriminate on the basis of age without violating the Fourteenth Amendment. The case concerned a lawsuit filed against the Florida Board of Regents, arguing that Florida State University had violated the Age Discrimination in Employment Act (ADEA) of 1967 by paying older librarians less than younger librarians. The Supreme Court affirmed the decision of the United States Court of Appeals for the Eleventh Circuit.[1][2][3]
Why it matters: The Supreme Court's decision in this case established that the Eleventh Amendment authorizes states to discriminate on the basis of age if it is related to state interest. To read more about the impact of Kimel v. Florida Board of Regents click here.
Background
The Age Discrimination in Employment Act (ADEA) of 1967 made it unlawful for employers to discriminate against individuals on the basis of age. The ADEA was extended to states in 1974.
A group of librarians from Florida State University filed a lawsuit against the Florida Board of Regents in 1995, arguing that the university had violated the ADEA by paying older librarians a lesser salary. The Board of Regents filed a motion to dismiss the case on the grounds that the Eleventh Amendment granted the state immunity. The district court denied the motion and held that Congress had abrogated the state's immunity by extending the law to the states. The United States Court of Appeals for the Eleventh Circuit held that the ADEA did not abrogate the state's immunity.[1][2]
Oral argument
Oral argument was held on October 13, 1999. The case was decided on January 11, 2000.[1]
Decision
The Supreme Court decided 5-4 to affirm the decision of the United States Court of Appeals for the Eleventh Circuit. Justice Sandra Day O'Connor delivered the opinion of the court. Justice John Paul Stevens wrote an opinion concurring in part and dissenting in part, joined by Justices David Souter, Ruth Bader Ginsburg, and Stephen Breyer. Justice Clarence Thomas also wrote an opinion concurring in part and dissenting in part, joined by Justice Anthony Kennedy.[2]
Opinions
Opinion of the court
Justice Sandra Day O'Connor, writing for the court, argued that the Age Discrimination in Employment Act did not abrogate the states' Eleventh Amendment immunity. O'Connor posited that states may discriminate on the basis of age in circumstances related to state interest without violating the Equal Protection Clause of the Fourteenth Amendment.[2]
| “ | Old age also does not define a discrete and insular minority because all persons, if they live out their normal life spans, will experience it. 427 U.S., at 313—314. Accordingly, as we recognized in Murgia, Bradley, and Gregory, age is not a suspect classification under the Equal Protection Clause. See, e.g., Gregory, supra, at 470; Bradley, supra, at 97; Murgia, supra, at 313—314.
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| —Sandra Day O'Connor, majority opinion in Kimel v. Florida Board of Regents[2] | ||
Concurring and dissenting opinions
Justice John Paul Stevens wrote an opinion concurring in part and dissenting in part, joined by Justices David Souter, Ruth Bader Ginsburg, and Stephen Breyer. Stevens argued that Congress had the authority to enforce federal law on state governments. [2]
| “ | Federalism concerns do make it appropriate for Congress to speak clearly when it regulates state action. But when it does so, as it has in these cases, we can safely presume that the burdens the statute imposes on the sovereignty of the several States were taken into account during the deliberative process leading to the enactment of the measure. Those burdens necessarily include the cost of defending against enforcement proceedings and paying whatever penalties might be incurred for violating the statute. In my judgment, the question whether those enforcement proceedings should be conducted exclusively by federal agencies, or may be brought by private parties as well, is a matter of policy for Congress to decide. In either event, once Congress has made its policy choice, the sovereignty concerns of the several States are satisfied, and the federal interest in evenhanded enforcement of federal law, explicitly endorsed in Article VI of the Constitution, does not countenance further limitations. There is not a word in the text of the Constitution supporting the Court’s conclusion that the judge-made doctrine of sovereign immunity limits Congress’ power to authorize private parties, as well as federal agencies, to enforce federal law against the States. The importance of respecting the Framers’ decision to assign the business of lawmaking to the Congress dictates firm resistance to the present majority’s repeated substitution of its own views of federalism for those expressed in statutes enacted by the Congress and signed by the President.[4] | ” |
| —John Paul Stevens, opinion in Kimel v. Florida Board of Regents[2] | ||
Justice Clarence Thomas also wrote an opinion concurring in part and dissenting in part, joined by Justice Anthony Kennedy. Thomas argued that Congress did not explicitly state its intention to abrogate states' immunity when it extended the Age Discrimination in Employment Act. [2]
| “ | Even if a clarifying amendment to an incorporated provision might sometimes provide a clear statement to abrogate for purposes of the Act into which the provision is incorporated, this is not such a case for two reasons. First, §626(b) does not clearly incorporate the part of §216(b) that establishes a private right-of-action against employers. Second, even assuming §626(b) incorporates §216(b) in its entirety, §216(b) itself falls short of an 'unmistakably clear' expression of Congress’ intent to abrogate the States’ Eleventh Amendment immunity from suit in federal court.[4] | ” |
| —Clarence Thomas, opinion in Kimel v. Florida Board of Regents[2] | ||
Impact
| Federalism |
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| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
- See also: Sovereign immunity
Kimel v. Florida Board of Regents established that states had the authority to discriminate on the basis of age. The case reaffirmed the states' Eleventh Amendment right to sovereign immunity, which protects state governments from civil suits, criminal prosecutions, or other legal actions.[2]
See also
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 1.2 Oyez, "Kimel v. Florida Board of Regents," accessed September 12, 2022
- ↑ 2.0 2.1 2.2 2.3 2.4 2.5 2.6 2.7 2.8 2.9 Justia, "Kimel v. Florida Bd. of Regents, 528 U.S. 62 (2000)," accessed September 12, 2022
- ↑ LexisNexis, "Kimel v. Fla. Bd. of Regents - 528 U.S. 62, 120 S. Ct. 631 (2000)," accessed September 12, 2022
- ↑ 4.0 4.1 4.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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