In 1972, Congress amended Title VII of the Civil Rights Act of 1964 to allow individuals to sue state governments for money damages for discrimination based on race, color, religion, sex, or national origin. Based on these amendments, Fitzpatrick and several other male state retirees (plaintiffs) sued Bitzer, Chairman of the Connecticut State Retirement Commission, and the State of Connecticut (defendants) for gender-based discrimination in Connecticut’s retirement policies. Fitzpatrick brought suit in district court. The district court granted only injunctive relief on the grounds that granting monetary relief under the Title VII Amendments violated state sovereignty as protected by the Eleventh Amendment. The court of appeals affirmed, and Fitzpatrick filed a petition for certiorari to the United States Supreme Court.