Fitzpatrick v. Bitzer
E114956
Fitzpatrick v. Bitzer is a 1976 U.S. Supreme Court decision holding that Congress may, under its Fourteenth Amendment enforcement powers, authorize private lawsuits for money damages against state governments despite Eleventh Amendment sovereign immunity.
All labels observed (3)
| Label | Occurrences |
|---|---|
| Fitzpatrick v. Bitzer canonical | 3 |
| Bitzer v. State of Connecticut, 519 F.2d 851 (2d Cir. 1975) | 1 |
| Fitzpatrick et al. v. Bitzer et al. | 1 |
How this entity was disambiguated
This entity first appeared as the object of triple T969470 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.
NED1
Entity disambiguation (via context triple)
gpt-5-mini-2025-08-07
Target entity: Fitzpatrick v. Bitzer Context triple: [Eleventh Amendment to the United States Constitution, keyCase, Fitzpatrick v. Bitzer]
-
A.
Bolling v. Sharpe
Bolling v. Sharpe is a 1954 U.S. Supreme Court case that held racial segregation in Washington, D.C. public schools unconstitutional under the Fifth Amendment’s Due Process Clause.
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B.
Printz v. United States
Printz v. United States is a 1997 U.S. Supreme Court decision that limited federal power by holding that Congress cannot compel state or local officials to implement federal regulatory programs.
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C.
Argersinger v. Hamlin
Argersinger v. Hamlin is a 1972 U.S. Supreme Court case that extended the right to counsel to defendants in misdemeanor cases that may result in imprisonment.
-
D.
Briggs v. Elliott
Briggs v. Elliott was a landmark federal court case from South Carolina challenging racial segregation in public schools, and it became one of the key cases consolidated into Brown v. Board of Education.
-
E.
Corrigan v. Buckley
Corrigan v. Buckley is a 1926 U.S. Supreme Court decision that upheld the enforceability of racially restrictive covenants in property deeds, paving the way for widespread legalized housing segregation until later overturned in effect by subsequent civil rights rulings.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
NED2
Entity disambiguation (via description)
gpt-5-mini-2025-08-07
Target entity: Fitzpatrick v. Bitzer Target entity description: Fitzpatrick v. Bitzer is a 1976 U.S. Supreme Court decision holding that Congress may, under its Fourteenth Amendment enforcement powers, authorize private lawsuits for money damages against state governments despite Eleventh Amendment sovereign immunity.
-
A.
Bolling v. Sharpe
Bolling v. Sharpe is a 1954 U.S. Supreme Court case that held racial segregation in Washington, D.C. public schools unconstitutional under the Fifth Amendment’s Due Process Clause.
-
B.
Printz v. United States
Printz v. United States is a 1997 U.S. Supreme Court decision that limited federal power by holding that Congress cannot compel state or local officials to implement federal regulatory programs.
-
C.
Argersinger v. Hamlin
Argersinger v. Hamlin is a 1972 U.S. Supreme Court case that extended the right to counsel to defendants in misdemeanor cases that may result in imprisonment.
-
D.
Briggs v. Elliott
Briggs v. Elliott was a landmark federal court case from South Carolina challenging racial segregation in public schools, and it became one of the key cases consolidated into Brown v. Board of Education.
-
E.
Corrigan v. Buckley
Corrigan v. Buckley is a 1926 U.S. Supreme Court decision that upheld the enforceability of racially restrictive covenants in property deeds, paving the way for widespread legalized housing segregation until later overturned in effect by subsequent civil rights rulings.
- F. None of above. chosen
Statements (47)
| Predicate | Object |
|---|---|
| instanceOf |
United States Supreme Court case
ⓘ
landmark sovereign immunity case ⓘ |
| areaOfLaw |
civil rights
ⓘ
constitutional law ⓘ federal courts ⓘ |
| arguedDate | 1976-03-29 ⓘ |
| causeOfAction | employment discrimination under Title VII ⓘ |
| citation | 427 U.S. 445 ⓘ |
| concurrenceBy |
John Paul Stevens
ⓘ
Lewis F. Powell Jr. ⓘ William J. Brennan Jr. ⓘ |
| country |
United States of America
ⓘ
surface form:
United States
|
| court | Supreme Court of the United States ⓘ |
| decidedDate | 1976-06-28 ⓘ |
| decisionDate | 1976-06-28 ⓘ |
| docketNumber | 75-251 ⓘ |
| fullCaseName |
Fitzpatrick v. Bitzer
self-linksurface differs
ⓘ
surface form:
Fitzpatrick et al. v. Bitzer et al.
|
| holding |
Congress may, pursuant to its enforcement powers under Section 5 of the Fourteenth Amendment, authorize private suits for money damages against state governments
ⓘ
The Eleventh Amendment does not bar private suits for money damages against a state when Congress has validly abrogated state sovereign immunity under Section 5 of the Fourteenth Amendment ⓘ |
| involvedStatute |
Equal Employment Opportunity Act of 1972
ⓘ
Title VII of the Civil Rights Act of 1964 ⓘ |
| joinedByInMajority |
Byron R. White
ⓘ
Lewis F. Powell Jr. ⓘ Potter Stewart ⓘ Thurgood Marshall ⓘ Warren E. Burger ⓘ William J. Brennan Jr. ⓘ |
| jurisdiction | federal question jurisdiction ⓘ |
| languageOfProceeding | English ⓘ |
| legalIssue |
Congressional power under Section 5 of the Fourteenth Amendment
ⓘ
Eleventh Amendment to the United States Constitution ⓘ
surface form:
Eleventh Amendment sovereign immunity
|
| majorityOpinionBy | William H. Rehnquist ⓘ |
| page | 445 ⓘ |
| plaintiffs | male employees of the State of Connecticut ⓘ |
| priorHistory |
Fitzpatrick v. Bitzer
self-linksurface differs
ⓘ
surface form:
Bitzer v. State of Connecticut, 519 F.2d 851 (2d Cir. 1975)
|
| relatedConstitutionalProvision |
Eleventh Amendment to the United States Constitution
ⓘ
Fourteenth Amendment ⓘ
surface form:
Fourteenth Amendment to the United States Constitution
Section 5 of the Fourteenth Amendment ⓘ |
| remedySought |
attorney’s fees
ⓘ
money damages ⓘ |
| reporter | United States Reports ⓘ |
| significance | recognized that the Civil War Amendments altered the federal-state balance regarding sovereign immunity ⓘ |
| stateParty | Connecticut ⓘ |
| subsequentCitation | cited as precedent in later Eleventh Amendment cases ⓘ |
| topic |
abrogation of state sovereign immunity
ⓘ
state liability for employment discrimination ⓘ |
| volume | 427 ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: Fitzpatrick v. Bitzer Description of subject: Fitzpatrick v. Bitzer is a 1976 U.S. Supreme Court decision holding that Congress may, under its Fourteenth Amendment enforcement powers, authorize private lawsuits for money damages against state governments despite Eleventh Amendment sovereign immunity.
Referenced by (5)
Full triples — surface form annotated when it differs from this entity's canonical label.
this entity surface form:
Fitzpatrick et al. v. Bitzer et al.
this entity surface form:
Bitzer v. State of Connecticut, 519 F.2d 851 (2d Cir. 1975)