Michael Leslie Lake v. Michael Skelton

The Eleventh Amendment to the United States Constitution provides States with immunity from being sued in federal court, but this immunity does not extend to cities, counties, or other municipal governments, unless they demonstrate that they acted as “an arm of the State” with respect to the conduct at issue. Mt. Healthy City Sch. Dist. Bd. of Educ. v. Doyle, 429 U.S. 274, 280 (1977). In this action, Petitioner Michael Lake sued Respondent Michael Skelton, in his official capacity as a deputy of the Cobb County Sheriff. The question presented, then, is whether county sheriffs in Georgia function as an arm of the State, and are thus entitled to Eleventh Amendment immunity, when they feed (or fail to properly feed) people detained in the county jail. See App. at 120.