Council 31 of the American Federation of State, County and Municipal Employees, AFL-CIO v. Quinn

Federal 7th Circuit Court
Civil Court
Eleventh Amendment
Citation
Case Number: 
No. 11-3111
Decision Date: 
May 17, 2012
Federal District: 
C.D. Ill.
Holding: 
Affirmed
In action by plaintiff-union alleging that defendant-Governor violated Contracts and Equal Protection Clauses by instituting pay freeze for certain State of Illinois employees, who were otherwise due pay raises under collective bargaining agreement, Dist. Ct. did not err in denying under defendant's assertion of 11th Amendment immunity, plaintiff's request for preliminary injunction, where essence of plaintiff's requested relief would require payment of funds out of State Treasury. Moreover, plaintiff failed to state valid Contracts Clause action where complaint failed to adequately allege that Rules adopted by defendant to enforce pay freeze unconstitutionally impaired collective bargaining agreement and/or plaintiff's ability to seek redress through arbitration. Also, plaintiff failed to allege valid Equal Protection claim where record demonstrated rational relationship between instant Rules and legitimate governmental purpose of cost savings.