Sato v. Orange County Dept. of Education

Summary

Michael Sato was hired by the Orange County Department of Education (OCDE) as a Systems Database Architect. After a few weeks of employment, Sat was terminated. He was provided no warning or explanation for his firing and not given an opportunity to be heard. Sato sued OCDE in federal district court. He asserted claims under 42 U.S.C. Section 1983 and state law, alleging that pursuant to his employment contract he could only be fired for cause. The court sided with OCDE, holding that it was an arm of the state and enjoyed Eleventh Amendment immunity from suit.

Affirmed. In Belanger v. Madera Unified School District and Eaglesmith v. Ward, this court held that California school districts and county offices of education were “arms of the state” entitled to state sovereign immunity. Sato argued that passage of AB 97 abrogated those decisions such that OCDE was no longer an arm of the state for sovereign immunity purposes. To assess whether AB 97 upended Belanger and Eaglesmith this court applied the five factors from Mitchell v. Los Angeles Community College District, which was used to determine whether a government entity was an arm of the state. Although “AB 97 reformed the financing and governance of California public schools in important ways, … it did not so fundamentally alter the relationship between COEs [county offices of education] and the state to abrogate … Belanger. Considering all the Mitchell factors together, OCDE remained an arm of the state and continued to enjoy Eleventh Amendment immunity. Thus, Sato’s claims were properly dismissed.

Opinion by Judge Richard C. Tallman.

— Maeda Riaz