Fitzpatrick v. Bitzer Case Brief

Why is the case important?

In 1972, Congress amended Title VII of the Civil Rights Act of 1964 (the Act), authorizing private suits for monetary damages. In doing so, Congress cited its authority under Section: 5 of the Fourteenth Amendment (Section:5 of the Fourteenth Amendment) of the United States Constitution (Constitution).

Facts of the case

Question

Can Congress abridge sovereign immunity by exercising its authority under Section: 5 of the Fourteenth Amendment?

Answer

Yes. Affirmed. The Supreme Court of the United States (Supreme Court) notes that Section: 5 of the Fourteenth Amendment allows Congress to exercise authority that infringes on areas otherwise relegated to other entities under the Constitution. Because of the Section: 5 grant of this authority, the Supreme Court allows Congress to abrogate sovereign immunity under the section, as well.

Conclusion

In allowing Congress to exercise this authority, the Court held that Section V of the 14th Amendment allows Congress to exercise authority that would otherwise infringe on areas under the responsibility of other entities, under the Constitution. However, because Section V has this grant of authority, the Supreme Court allowed Congress to abrogate sovereign immunity of the states as well.

  • Case Brief: 1976
  • Petitioner: Fitzpatrick
  • Respondent: Bitzer
  • Decided by: Burger Court

Citation: 427 US 445 (1976)
Argued: Apr 20 – 21, 1976
Decided: Jun 28, 1976