State judicial
district is a state agency for purposes of Eleventh Amendment immunity from
ADA claim.
Benn v. First Judicial
Dist. of Pa., 426 F.3d 233 (3d Cir. October 12, 2005) - This is an ADA
action. Donald Benn was a probation and parole officer for the First
Judicial District ("Judicial District"). The Pennsylvania court system is
divided into 60 judicial districts. The main issue presented is whether the
Judicial District is a state agency and therefore entitled to Eleventh
Amendment immunity. In Board of Trustees
of the University of Alabama v. Garrett, 531 U.S. 356 (2001), the U.S.
Supreme Court held that Congress did not validly abrogate Eleventh Amendment
immunity when it enacted Title I of the ADA. In addition, a suit may be
barred by the Eleventh Amendment even though a state is not named a party to
the action, so long as the state is deemed to be the real party in interest.
The Court holds that the Pennsylvania Constitution envisions a unified state
judicial system, of which the Judicial District is an integral component. As
a result, the Court finds that Pennsylvania is a real party in interest and
the Judicial District has Eleventh Amendment immunity from Benn's ADA claim.
