Sato v. Orange County Department of Education, No. 15-56402 (9th Cir. 2017)
Annotate this CaseThe passage of Assembly Bill 97, a massive reform package designed to streamline public education financing and decentralize education governance, did not abrogate the Ninth Circuit's decisions in which the panel held that California school districts and county offices of education (COEs) are "arms of the state" entitled to state sovereign immunity. Applying the factors set forth in Mitchell v. Los Angeles Community College District, 861 F.2d 198, the panel held that school districts and COEs in California remain arms of the state and cannot face suit. Accordingly, the panel affirmed the dismissal of plaintiff's lawsuit against the Orange County Department of Education where plaintiff alleged claims related to his termination with the Department.
Court Description: Civil Rights The panel affirmed the district court’s dismissal of a lawsuit brought pursuant to 42 U.S.C. § 1983 and state law by a former employee of the Orange County Department of Education who alleged that his termination violated his Fourteenth Amendment substantive and procedural due process rights and constituted a breach of contract. The district court found that the Orange County Department of Education, as an arm of the state, was immune from suit under the Eleventh Amendment. In affirming the district court, the panel rejected plaintiff’s contention that California Assembly Bill 97, which streamlined public education financing and decentralized education governance, abrogated the holding in Belanger v. Madera Unified School District, 963 F.2d 248 (9th Cir. 1992), that California school districts are entitled to sovereign immunity. Applying the factors set forth in Mitchell v. Los Angeles Community College District, 861 F.2d 198 (9th Cir. 1988), the panel held that California school districts and County Offices of Education remain arms of the state and continue to enjoy Eleventh Amendment immunity. The panel held that AB 97 reformed the financing and governance of California public schools in important ways, but it did not so fundamentally alter the relationship between Offices of
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