Papasan v. Allain

Summary

The Court held that the Eleventh Amendment barred claims seeking restoration of Mississippi's lost school-land trust assets or replacement income, but did not bar prospective relief against an ongoing unequal distribution of school-land benefits. Rational-basis review governed the equal protection claim because the complaint supplied no facts supporting its assertion that children were denied a minimally adequate education. Rodriguez did not resolve the constitutionality of this particular distribution of state resources. The Court therefore affirmed dismissal of the trust and related claims, vacated dismissal of the equal protection claim, and remanded. Brennan, joined by Marshall, Blackmun, and Stevens, joined Parts I and III and concurred in the result in Part II-C, but dissented from the sovereign-immunity analysis and dismissal of the trust claims. Blackmun separately argued that Mississippi's acceptance of federal benefits could constitute consent to suit and would revive the trust claims. Powell, joined by Burger and Rehnquist, agreed with Part II but would affirm dismissal of the equal protection claim because overall funding data undermined any claim of educational detriment.