Facts of the Case
Title VII of the Civil Rights Act of 1964 includes the states as covered employers. Current and retired male employees of the state of Connecticut sued the state in federal court on the grounds that its statutory retirement plan violated the Civil Rights Act by discriminating against them based on their gender. While the federal district court ruled in part for the employees, it held that the Eleventh Amendment prevented them from receiving back pay. On appeal, the court ruled that the Fourteenth Amendment may not be enforced through a private action for retroactive damages.
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