Mt. Healthy City School District Board of Education v. Doyle

Mt. Healthy City School District Board of Education v. Doyle (1977) 429 U.S. 274, 280 97 S.Ct. 568, 572, 50 L.Ed.2d 471, is particularly relevant here because it involved a local school board. In Mt. Healthy, the court held an Ohio city school board did not enjoy Eleventh Amendment immunity, because the board was "more like a county or city than . . . like an arm of the State." (Id., at p. 280 97 S. Ct. at p. 573.) It noted that under state law school districts were political subdivisions, and the state did not include political subdivisions. Furthermore, although the school board was subject to "some" guidance from the State Board of Education and received "a significant amount of money" from the state, it also had extensive powers to issue bonds and to levy taxes within certain restrictions. (Id., at p. 280 97 S. Ct. at p. 573.)