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Felicia Pellitteriv.Sheriff Chris Prine

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.13-14297
DecidedJanuary 13, 2015
Reporter776 F.3d 777; 2015 U.S. App. LEXIS 464
JudgesEleventh Circuit Judges Martin, Julie Carnes, and Black
Tags
CivilGovernment LawCivil RightsEmployment LawEmployment DiscriminationAmericans with Disabilities ActSection 1983Sovereign ImmunityStatutory InterpretationReversalRemand
Case Summary

Felicia Pellitteri alleged that Sheriff Chris Prine and county defendants denied her light-duty accommodation after a work injury and fired her, in violation of federal law. Prine appealed the denial of his motion to dismiss the official-capacity claims, arguing that Eleventh Amendment immunity barred Pellitteri’s wrongful-termination claims. Applying the function-specific arm-of-the-State test, the Eleventh Circuit held that a Georgia sheriff acts for the State when hiring and firing deputies: state law supplies and regulates that authority, while county funding and responsibility for judgments did not outweigh the other factors. The court reversed the denial of Prine’s motion to dismiss as to the official-capacity claims under § 1983 and the ADA and remanded for further proceedings.

Opinion

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