Sovereign Immunity-Young Doctrine Exception

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7^th Circuit Court of Appeals

Case Name: Jeremiah C. Sherwood v. Raymond P. Marchiori

Case No.: 22-2859

Officials: Flaum, Brennan, and St. Eve, Circuit Judges.

Focus: Sovereign Immunity-Young Doctrine Exception

In March of 2020, Sherwood and Doyle found themselves unemployed due to the repercussions of the COVID-19 pandemic. Consequently, they submitted applications for unemployment benefits. Despite their efforts, they never received the expected benefits, and up until the present time, they have not been officially informed of the denial of their claims or been given the opportunity for a formal hearing. In response, Sherwood and Doyle initiated a class action lawsuit against the Director of the Illinois Department of Employment Security (IDES), asserting claims related to equal protection and procedural due process violations.

The Seventh Circuit upholds dismissal. Operating within the “Young doctrine,” which presents an exception to Eleventh Amendment immunity, private parties retain the ability to sue individual state officials for potential remedies intended to prevent ongoing violations of federal law. Even if the plaintiffs demonstrated standing to present their equal protection claims, sovereign immunity acts as a barrier. The Young exception doesn’t apply in cases where federal law violations have occurred only at a single point in time or within a past timeframe. While the plaintiffs have raised a valid injury to pursue their procedural due process claims and have the option to invoke the Young exception against sovereign immunity, the availability of mandamus provides a sufficient remedy under state law in this particular instance.

Affirmed

Decided 08/07/23

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