Virginia Office for Protection and Advocacy v. Stewart

Two federal disability-rights laws (the federal laws) offered money to states to improve services for people with developmental disabilities and mental illnesses. To receive the money, states had to establish public or private protection-and-advocacy systems to protect and advocate for disabled people. The entities had to be independent from state governments. Under the federal laws, the entities had to have authority to investigate alleged abuse and neglect and had to be given access to all relevant records. Further, the entities had to have the authority to pursue legal and administrative remedies on behalf of those with disabilities. Virginia established the Virginia Office for Protection and Advocacy (VOPA) (plaintiff) to fulfill the obligations of the federal laws. VOPA acted independently of the Virginia state government and had authority to initiate proceedings to protect the rights of disabled people. In 2006 VOPA began investigating deaths that occurred in state-operated mental hospitals. Pursuant to the federal laws, VOPA asked officials in charge of the hospitals (the hospital administrators) (defendants) to produce relevant records. The hospital administrators refused. VOPA sued the hospital administrators in federal district court, arguing the federal laws entitled it to the requested records. VOPA sought an injunction requiring the hospital administrators to produce the records. The hospital administrators moved to dismiss the action, arguing they were immune from suit under the Eleventh Amendment to the United States Constitution. The district court denied the motion, finding that VOPA had authority to sue the hospital administrators under the Ex Parte Young exception to sovereign immunity. The court of appeals reversed the district court and dismissed the case. VOPA appealed.