Sato v. Orange County Department of Education

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The passage of Assembly Bill 97, a massive reform package designed to streamline public education financing and decentralize education governance, did not abrogate the Ninth Circuit's decisions in which the panel held that California school districts and county offices of education (COEs) are "arms of the state" entitled to state sovereign immunity. Applying the factors set forth in Mitchell v. Los Angeles Community College District, 861 F.2d 198, the panel held that school districts and COEs in California remain arms of the state and cannot face suit. Accordingly, the panel affirmed the dismissal of plaintiff's lawsuit against the Orange County Department of Education where plaintiff alleged claims related to his termination with the Department. View "Sato v. Orange County Department of Education" on Justia Law