Torres v. Texas Department of Public Safety

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Supreme Court of the United States
Torres v. Texas Department of Public Safety
Term: 2021
Important Dates
Argued: March 29, 2022
Decided: June 29, 2022
Outcome
Reversed and remanded
Vote
5-4
Majority
Stephen Breyer • Chief Justice John Roberts • Sonia Sotomayor • Elena Kagan • Brett Kavanaugh
Concurring
Elena Kagan
Dissenting
Clarence Thomas • Samuel Alito • Neil Gorsuch • Amy Coney Barrett

Torres v. Texas Department of Public Safety is a case that was decided by the Supreme Court of the United States on June 29, 2022, during the court's October 2021-2022 term. The case was argued before the court on March 29, 2022.

In a 5-4 ruling, the court reversed the decision of the Texas Thirteenth District Court of Appeals and remanded the case for further proceedings, holding that "by ratifying the Constitution, the States agreed their sovereignty would yield to the national power to raise and support the Armed Forces. Congress may exercise this power to authorize private damages suits against nonconsenting States, as in USERRA."[1] Justice Stephen Breyer delivered the majority opinion of the court. Justice Clarence Thomas filed a dissenting opinion, joined by Justices Samuel Alito, Neil Gorsuch, and Amy Coney Barrett. Click here for more information about the ruling.

HIGHLIGHTS
  • The case: The petitioner Le Roy Torres served in the U.S. Army and is a former state trooper in Texas. While deployed, Torres sustained lung damage. Upon his honorable discharge, Torres sought employment with the Texas Department of Public Safety (DPS) but requested to be placed in a different position other than as a state trooper, as his lung damage precluded him from performing all of his duties. DPS declined the request and offered him a temporary position as a state trooper, stating that if he did not report to duty, his employment would be terminated. Torres resigned. Later, he sued DPS in state court for violating the Uniformed Services Employment and Reemployment Rights Act of 1994 (USERRA) by not accommodating him. DPS moved to dismiss the case, citing sovereign immunity from USERRA lawsuits. The trial court denied the motion. On appeal, the Texas Thirteenth District Court of Appeals granted DPS' motion. Torres appealed the ruling to the U.S. Supreme Court. Click here to learn more about the case's background.
  • The issue: The case concerned the Uniformed Services Employment and Reemployment Rights Act of 1994 (USERRA) and sovereign immunity.
  • The questions presented: Whether U.S. Congress has the authority to authorize lawsuits against nonconsenting states according to its constitutional war powers.[2]
  • The outcome: The U.S. Supreme Court reversed the decision of the Texas Thirteenth District Court of Appeals and remanded the case for further proceedings.


    • The case came on a writ of certiorari to the Texas Thirteenth District Court of Appeals. To review the lower court's opinion, click here.[3]

    Timeline

    The following timeline details key events in this case:

    • June 29, 2022: The U.S. Supreme Court reversed the decision of the Texas Thirteenth District Court of Appeals and remanded the case for further proceedings.
    • March 29, 2022: The U.S. Supreme Court heard oral argument.
    • December 15, 2021: The U.S. Supreme Court agreed to hear the case.
    • November 2, 2020: Le Roy Torres appealed to the U.S. Supreme Court.
    • June 5, 2020: The Texas Supreme Court denied review in the case.
    • November 20, 2018: The Texas Thirteenth District Court of Appeals reversed the trial court's order and granted the Texas Department of Public Safety's (DPS) jurisdictional sovereign immunity plea.

    Background

    The petitioner Le Roy Torres enlisted in the U.S. Army Reserve in 1989. While serving as an army reservist, Torres was employed as a state trooper for the Texas Department of Public Safety (DPS). In 2007, he was called to active duty and deployed to Iraq. While serving, Torres sustained lung damage attributed to exposure to toxic fumes on military bases. Later, Torres was diagnosed with constrictive bronchiolitis. In 2008, Torres was honorably discharged. He notified DPS of his intent to be employed and stated that his lung damage prevented him from performing all of his duties as a state trooper. He requested that DPS put him in a different departmental position. DPS denied the accommodation request and offered him a temporary position as a state trooper. DPS stipulated that his employment would be terminated if he did not report to duty. Torres resigned.[2][3]

    In 2017, Torres sued DPS in state court for violating the Uniformed Services Employment and Reemployment Rights Act of 1994 (USERRA) by not offering him a position that would accommodate his disability. DPS moved to dismiss the case, arguing that Texas had sovereign immunity from lawsuits under USERRA. The trial court denied DPS' motion.

    On appeal, the Texas Thirteenth District Court of Appeals reversed the trial court's order and granted the Texas Department of Public Safety's (DPS) jurisdictional sovereign immunity plea. The court issued its ruling on November 20, 2018.

    On June 5, 2020, the Texas Supreme Court denied review in the case.

    On November 2, 2020, Le Roy Torres appealed to the U.S. Supreme Court, asking for the court to consider whether U.S. Congress has the authority to authorize lawsuits against nonconsenting states according to its constitutional war powers.[2] On December 15, 2021, SCOTUS agreed to hear the case argued on the merits during its 2021-2022 term.

    Sovereign immunity

    Sovereign immunity is the idea that the sovereign or government is immune from civil suits, criminal prosecutions or other legal actions except when it consents to them. Derived from early English law, sovereign immunity was once an absolute doctrinal position that held Federal, state, and local governments immune from tort liability arising from the activities of government. Today, the application of sovereign immunity is more ambiguous, as different governments have waived liability in differing degrees depending on the circumstances.[4][5]

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented: Whether U.S. Congress has the authority to authorize lawsuits against nonconsenting states according to its constitutional war powers.

    Oral argument

    Audio

    Audio of oral argument:[6]



    Transcript

    Transcript of oral argument:[7]

    Outcome

    In a 5-4 ruling, the court reversed the decision of the Texas Thirteenth District Court of Appeals and remanded the case for further proceedings, holding that "by ratifying the Constitution, the States agreed their sovereignty would yield to the national power to raise and support the Armed Forces. Congress may exercise this power to authorize private damages suits against nonconsenting States, as in USERRA."[1] Justice Stephen Breyer delivered the majority opinion of the court. Justice Clarence Thomas filed a dissenting opinion, joined by Justices Samuel Alito, Neil Gorsuch, and Amy Coney Barrett.


    Opinion

    In the court's majority opinion, Justice Stephen Breyer wrote:[1]

    “ The Constitution vests in Congress the power “[t]o raise and support Armies” and “[t]o provide and maintain a Navy.” Art. I, §8, cls. 1, 12–13. Pursuant to that authority, Congress enacted a federal law that gives returning veterans the right to reclaim their prior jobs with state employers and authorizes suit if those employers refuse to accommodate them. See Uniformed Services Employment and Reemployment Rights Act of 1994 (USERRA), 38 U. S. C. §4301 et seq. This case asks whether States may invoke sovereign immunity as a legal defense to block such suits.


    In our view, they cannot. Upon entering the Union, the States implicitly agreed that their sovereignty would yield to federal policy to build and keep a national military. States thus gave up their immunity from congressionally authorized suits pursuant to the “ ‘plan of the Convention,’ ” as part of “ ‘the structure of the original Constitution itself.’ ” PennEast Pipeline Co. v. New Jersey, 594 U. S. ___, ___ (2021) (slip op., at 14) (quoting Alden v. Maine, 527 U. S. 706, 728 (1999)).[8]

    		”
    —Justice Stephen Breyer

    Concurring opinion

    Justice Elena Kagan filed a concurring opinion.

    In her concurrence, Justice Kagan wrote:[1]

    “ In my view, our sovereign immunity decisions have not followed a straight line. Two years ago, I described Katz’s “plan of the Convention” analysis as “good for one clause only”—i.e., Article I’s Bankruptcy Clause. Allen v. Cooper, 589 U. S. ___, ___–___ (2020) (slip op., at 8–9) (hyphens omitted); see Central Va. Community College v. Katz, 546 U. S. 356, 373–379 (2006). I thought then that our precedents had shut the door on further Article I exceptions to state sovereign immunity. But PennEast proved me wrong. See PennEast Pipeline Co. v. New Jersey, 594 U. S. ___ (2021). The question there was whether the States had consented in the plan of the Convention to the Federal Government’s exercise of Article I’s eminent domain power, including through private parties’ suits. Relying on our prior decisions, I concluded that the States had not so consented. See id., at ___–___ (BARRETT , J., dissenting) (slip op., at 1– 4). But the Court ruled otherwise. Using a new test, it held that the eminent domain power was “complete in itself,” meaning that the States had “consented to the [federal] exercise of that power[ ] in its entirety.” Id., at ___ (slip op., at 22). The question today, given PennEast, is whether the same is true of the war powers. Were those powers also “complete in themselves,” so that the States likewise consented to congressionally authorized private litigation?


    The answer is yes, as the Court holds. Much more than eminent domain, war powers lie at the heart of the Convention’s plan. The overriding goal of the Convention was “to create a cohesive national sovereign in response to the failings of the Articles of Confederation.” Ibid. And among those failings, none was more important than “the want of power in Congress to raise an army and the dependence upon the States” to provide armed forces. Selective Draft Law Cases, 245 U. S. 366, 381 (1918). For that reason, the war powers—more than any other power, and surely more than eminent domain—were “complete in themselves.” They were given by the States, entirely and exclusively, to the Federal Government. See ante, at 7–12; U. S. Const., Art. I, §8, cls. 11–16, §10, cls. 1, 3. PennEast’s analysis thus compels today’s result. In setting out the “complete in itself ” test, the Court there answered the question here: At the Convention, the States waived their sovereign immunity to any suit Congress authorized under the war powers.[8]

    		”
    —Justice Elena Kagan

    Dissenting opinion

    Justice Clarence Thomas filed a dissenting opinion, joined by Justices Samuel Alito, Neil Gorsuch, and Amy Coney Barrett.

    In his dissent, Justice Thomas wrote:[1]

    “ More than two decades ago, this Court found it “difficult to conceive that the Constitution would have been adopted if it had been understood to strip the States of immunity from suit in their own courts and cede to the Federal Government a power to subject nonconsenting States to private suits in these fora.” Alden v. Maine, 527 U. S. 706, 743 (1999). Accordingly, we held—without qualification—that “the powers delegated to Congress under Article I of the United States Constitution do not include the power to subject nonconsenting States to private suits for damages in state courts.” Id., at 712 (emphasis added).


    No longer. Today, by adopting contrived interpretations of Alden and the recent decision in PennEast Pipeline Co. v. New Jersey, 594 U. S. ___ (2021), the Court holds that at least two (and perhaps more) Article I “war powers” do, in fact, include “the power to subject nonconsenting States to private suits for damages in state courts,” Alden, 527 U. S., at 712, and that Congress has exercised that power by enacting the Uniformed Services Employment and Reemployment Rights Act of 1994 (USERRA), 38 U. S. C. §4301 et seq. Alden should have squarely foreclosed that holding. As the Court there already explained, constitutional text, history, and precedent all show that when the States ratified the Constitution, they did not implicitly consent to private damages actions filed in their own courts—whether authorized by Congress’ war powers or any other Article I power. Because the Court today holds otherwise, I respectfully dissent.[8]

    		”
    —Justice Clarence Thomas

    Text of the opinion

    Read the full opinion here.

    October term 2021-2022

    See also: Supreme Court cases, October term 2021-2022

    The Supreme Court began hearing cases for the term on October 4, 2021. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[9]

    The court agreed to hear 68 cases during its 2021-2022 term.[10] Four cases were dismissed and one case was removed from the argument calendar.[11]

    The court issued decisions in 66 cases during its 2021-2022 term. Three cases were decided without argument. Between 2007 and 2021, SCOTUS released opinions in 1,128 cases, averaging 75 cases per year.


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 U.S. Supreme Court, Torres v. Texas Department of Public Safety, decided June 29, 2022
    2. ↑ 2.0 2.1 2.2 2.3 U.S. Supreme Court, "Torres v. Texas Department of Public Safety: PETITION FOR A WRIT OF CERTIORARI," filed November 2, 2020
    3. ↑ 3.0 3.1 Texas Thirteenth District Court of Appeals, Tex. Dep't of Pub. Safety v. Torres, decided Nov 20, 2018
    4. ↑ Cornell University Law School: Wex Legal Dictionary and Encyclopedia, Sovereign immunity definition
    5. ↑ U.S. Legal: Sovereign immunity definition
    6. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued March 29, 2022
    7. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued March 29, 2022
    8. ↑ 8.0 8.1 8.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    9. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed February 4, 2021
    10. ↑ Consolidated cases are counted as one case for purposes of this number.
    11. ↑ U.S. Supreme Court, "Order List: 593 U.S.," May 17, 2021
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