In Howlett v. Rose (1990) 496 U.S. 356, a civil rights case, a former high school student filed suit in state court under 42 United States Code section 1983 against the school board and three school officials. The case was dismissed on the basis of immunity. The United States Supreme Court reversed, concluding state law immunity may not be invoked where a sovereign immunity defense would not be available in federal court. According to the high court, "the elements of, and the defenses to, a federal cause of action are defined by federal law." ( Howlett v. Rose, supra, 496 U.S. at p. 375 110 L. Ed. 2d at p. 353.)