In Manders v. Lee, the United States Court of Appeals for the Eleventh Circuit held that a Georgia county sheriff is an arm of the state when acting in his official capacity in implementing and enforcing use-of-force guidelines and, thus, is immune from suit in federal court under the Eleventh Amendment.' This decision creates considerable uncertainty in the area of government-entity liability under 42 U.S.C. § 19833 because of the potentially broad impact of this newly established analytical approach.
Ward, Thomas B.
"Finding Immunity: Manders v. Lee and the Erosion of § 1983 Liability,"
Mercer Law Review: Vol. 55:
4, Article 19.
Available at: https://digitalcommons.law.mercer.edu/jour_mlr/vol55/iss4/19