Wedlake v. The State of South Carolina

CourtDistrict Court, D. South Carolina
DecidedOctober 16, 2020
Docket6:20-cv-02085
StatusUnknown

This text of Wedlake v. The State of South Carolina (Wedlake v. The State of South Carolina) is published on Counsel Stack Legal Research, covering District Court, D. South Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wedlake v. The State of South Carolina, (D.S.C. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA GREENVILLE DIVISION

Raymond A. Wedlake, ) Case No. 6:20-cv-02085-DCC ) Plaintiff, ) ) v. ) ORDER ) ) The State of South Carolina as ) Represented by the Honorable Alan ) Wilson, Attorney General, ) ) Defendant. ) ________________________________ )

This matter is before the Court upon Plaintiff’s complaint. ECF No. 1. In accordance with 28 U.S.C. § 636(b) and Local Civil Rule 73.02(B)(2) (D.S.C.), this matter was referred to United States Magistrate Judge Jacquelyn D. Austin for pre-trial proceedings and a Report and Recommendation (“Report”). On July 10, 2020, Defendant filed a motion to dismiss. ECF No. 13. On August 27, 2020, the Magistrate Judge issued a Report recommending that the motion be granted. ECF No. 22. Plaintiff filed objections to the Report, and Defendant filed a reply. ECF Nos. 25, 27. APPLICABLE LAW The Magistrate Judge makes only a recommendation to this Court. The recommendation has no presumptive weight, and the responsibility to make a final determination remains with the Court. See Mathews v. Weber, 423 U.S. 261 (1976). The Court is charged with making a de novo determination of any portion of the Report of the Magistrate Judge to which a specific objection is made. The Court may accept, reject, or modify, in whole or in part, the recommendation made by the Magistrate Judge or recommit the matter to the Magistrate Judge with instructions. See 28 U.S.C. § 636(b).

The Court will review the Report only for clear error in the absence of an objection. See Diamond v. Colonial Life & Accident Ins. Co., 416 F.3d 310, 315 (4th Cir. 2005) (stating that “in the absence of timely filed objection, a district court need not conduct a de novo review, but instead must only satisfy itself that there is no clear error on the face of the record in order to accept the recommendation.” (citation omitted)).

ANALYSIS The Magistrate Judge has provided a thorough recitation of the facts and relevant law, which the Court incorporates into this Order by reference. Plaintiff seeks a declaratory judgment that “violations of the US Constitution by the SC Code of Law [Homeowners’ Association] Act are unconstitutional, violate Plaintiff’s religious beliefs and rights by forcibly requiring him to participate as a member of the [Woodington

Homeowners’ Association] and to pay unwanted dues and assessments” making “Section 27-30-120(b) null and void.” ECF No. 1 at 3. As previously stated, the Magistrate Judge recommends dismissal of all of Plaintiff’s claims. The Magistrate Judge recommends finding that Defendant is entitled to immunity pursuant to the Eleventh Amendment. ECF No. 22. Plaintiff objects and argues that the

Eleventh Amendment only applies to monetary damages and that the exception to Eleventh Amendment immunity recognized in Ex parte Young, 209 U.S. 123 (1908), is applicable to this action. ECF No. 25. The Court disagrees. The Eleventh 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

one of the United States by citizens of another state, or by citizens or subjects of any foreign state.” U.S. Const. amend. XI. Though not explicitly stated in the language of the amendment, courts have long held that this guarantee also protects a state from federal suits brought by its own citizens, not only from suits by citizens of other states. Port Auth. Trans-Hudson Corp. v. Feeney, 495 U.S. 299, 304 (1990). “The ultimate guarantee of

the Eleventh Amendment is that non-consenting States may not be sued by private individuals in federal court.” Bd. of Trustees of Univ. of Ala. v. Garrett, 531 U.S. 356, 363, (2001). Sovereign immunity under the Eleventh Amendment “is concerned not only with the States’ ability to withstand suit, but with their privilege not to be sued” in the first instance. Alabama v. North Carolina, 560 U.S. 330, 362 (2010) (quoting P.R. Aqueduct and Sewer Auth. v. Metcalf & Eddy, Inc., 506 U.S. 139, 147, n.5 (1993)). State agencies

and state employees acting in their official capacities that may be properly characterized as arms of the State are also entitled to the same immunity as the state itself. Harter v. Vernon, 101 F.3d 334, 337 (4th Cir. 1996) (citing Mt. Healthy City Bd. of Ed. v. Doyle, 429 U.S. 274, 280 (1977) (internal quotation marks omitted)). A claim asserted against a state or state agency “may survive the Eleventh

Amendment bar in one of three recognized ways”: (1) “Congress may abrogate state Eleventh Amendment immunity”; (2) “a state may waive its immunity”; or (3) “a plaintiff may seek prospective relief against state officials acting in violation of federal law under the principles set forth in Ex parte Young”. Pickering v. State Police, 59 F. Supp. 3d 742, 747 (E.D. Va. 2014). Under the Ex parte Young exception to Eleventh Amendment immunity, a federal court may “issue prospective, injunctive relief against a state officer

to prevent ongoing violations of federal law, on the rationale that such a suit is not a suit against the state for purposes of the Eleventh Amendment.” McBurney v. Cuccinelli, 616 F.3d 393, 399 (4th Cir. 2010). The Fourth Circuit has explained that “[t]he Ex parte Young exception is directed at ‘officers of the state [who] are clothed with some duty in regard to the enforcement of the laws of the state, and who threaten and are about to commence

proceedings . . . to enforce against parties affected [by] an unconstitutional act.’” Id. (alterations in original) (quoting Ex parte Young, 209 U.S. at 155–56). In order for the Ex parte Young exception to apply, a “special relation” must exist “between the state officer sued and the challenged statute to avoid the Eleventh Amendment’s bar.” Waste Mgmt. Holdings, Inc. v. Gilmore, 252 F.3d 316, 331 (4th Cir. 2001) (quoting Ex parte Young, 209 U.S. at 157). This “special relation” “requires

proximity to and responsibility for the challenged state action.” Wright v. North Carolina, 787 F.3d 256, 261–62 (4th Cir. 2015) (quoting S.C. Wildlife Fed’n v. Limehouse, 549 F.3d 324, 333 (4th Cir. 2008)). However, “[g]eneral authority to enforce the laws of the state is not sufficient to make government officials the proper parties to litigation challenging the law.” Waste Mgmt., 252 F.3d at 331 (emphasis added) (citation omitted).

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Related

Ex Parte Young
209 U.S. 123 (Supreme Court, 1908)
Mathews v. Weber
423 U.S. 261 (Supreme Court, 1976)
Port Authority Trans-Hudson Corp. v. Feeney
495 U.S. 299 (Supreme Court, 1990)
Board of Trustees of Univ. of Ala. v. Garrett
531 U.S. 356 (Supreme Court, 2001)
Alabama v. North Carolina
560 U.S. 330 (Supreme Court, 2010)
McBurney v. Cuccinelli
616 F.3d 393 (Fourth Circuit, 2010)
South Carolina Wildlife Federation v. Limehouse
549 F.3d 324 (Fourth Circuit, 2008)
Hutto v. South Carolina Retirement System
773 F.3d 536 (Fourth Circuit, 2014)
Calla Wright v. State of North Carolina
787 F.3d 256 (Fourth Circuit, 2015)
Harter v. Vernon
101 F.3d 334 (Fourth Circuit, 1996)
Shaw v. Stroud
13 F.3d 791 (Fourth Circuit, 1994)
Pickering v. Virginia State Police
59 F. Supp. 3d 742 (E.D. Virginia, 2014)

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Wedlake v. The State of South Carolina, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wedlake-v-the-state-of-south-carolina-scd-2020.