Nodoushani v. Southern Connecticut State University
The 11th Amendment provides, "The Judicial power of the United States shall not be construed to extend to any suit in law or equity, commenced or prosecuted against any one of the United States by Citizens of another State, or by Citizens or Subjects of any Foreign State." The plaintiff, Omid Nodoushani, sued the Southern Connecticut State University, alleging workplace discrimination and retaliation, in violation of Title VII of the Civil Rights Act of 1964 and the Connecticut Fair Employment Practices Act. Nodoushani also alleged intentional infliction of emotional distress. The District Court, Thompson, J., granted the university's motion for summary judgment. Nodoushani appealed to the 2nd Circuit. The 2nd Circuit reviewed de novo. The 2nd Circuit held that the District Court did not err when it found that the 11th Amendment barred the plaintiff's state claims. "Given that explicit limitation on judicial power, wrote the 2nd Circuit, "the district court correctly ruled that Nodoushani's state claims are barred by the Eleventh Amendment." The 2nd Circuit also observed that the District Court possessed the option to dismiss Nodoushani's state claims without prejudice, because the District Court lacked subject-matter jurisdiction. The 2nd Circuit affirmed the District Court's judgment with respect to Nodoushani's Title VII claims.