No, not that JQA. (Sorry for the clickbaitey headline.) But who could resist the Fifth Circuit's per curiam opinion in John Quincy Adams v. Pearl River Valley Water Supply District, No. 21-60749 (July 20, 2022) which held that Mr. Adams, who owned property near a reservoir, could not sue state officials in federal court for injunctive relief for due process violations and takings.
Adams alleged that Mississippi water district officials were violating a state statute by not allowing him to exercise the option to re-acquire property that the water district had condemned decades earlier. His federal court complaint avoided directly asking for money damages because those claims would mean the state officials would have Eleventh Amendment immunity. Instead, "[t]he Adamses requested a declaratory judgment that the District’s sales and leases of property without notice were ongoing constitutional violations and asked the court to fashion whatever injunctive relief it deemed necessary to correct the violations going forward, including ancillary monetary relief." Slip op. at 4.
Motion to dismiss for lack of jurisdiction granted, and the Fifth Circuit affirmed.
But doesn't the Ex parte Young exception to the usual rule that you can't sue state officials in their official capacities in federal court apply? After all, Adams sought to enjoin what he claimed were ongoing violations, which counts as prospective injunctive relief, right? Not here, the Fifth Circuit concluded, because although Adams alleged that the officials had violated his rights in the past, he had not alleged enough to show that they would do so again:
Once any claims for monetary relief were properly dismissed because of sovereign immunity, all that remains was in essence a demand for the court to order the District to comply with state law in the future as to any of the family’s former land. Even if the Adamses’ rights were violated in the past, the Adamses have at best offered “[a]llegations of possible future injury” that they have not claimed is imminent, or “certainly impending,” or anything other than speculative. See Clapper, 568 U.S. at 409 (quotation marks and citation omitted).
Slip op. at 7.
One correction to the district court's dismissal: the Fifth Circuit noted the dismissal should have been made without prejudice.
John Quincy Adams v. Pearl River Valley Water Supply Dist., No. 21-60749 (5th Cir. July 20, 2022) (per curi...
