California School Districts and County Offices of Education Remain Arms of the State That Cannot Be Sued under 43 U.S.C. section 1983

In Sato v. Orange County Department of Education, the 9th Circuit Court of Appeals rejected an argument that AB 97, a legislative reform package designed to decentralize education in California, changed previous rulings that California school districts and County Offices of Education are arms of the state, and so immune under the Eleventh Amendment from suits under 42 U.S.C. section 1983.