Howlett (plaintiff), a Florida high school student, brought an action in the Circuit Court for Pinellas County under 42 U.S.C. § 1983 against the county school board and three school officials including Rose (defendants). Howlett’s complaint alleged violations of the Fourth and Fourteenth Amendments of the United States Constitution and like provisions of the Florida Constitution. The court dismissed his suit on the grounds that Florida had not waived its sovereign immunity so as to permit a state court to hear a § 1983 action against a school district. Florida circuit courts had in the past, however, entertained § 1983 suits against individual public officials, similar state-law claims against state defendants, and tort suits by private citizens against state entities including school boards. Howlett petitioned the United States Supreme Court for certiorari.