Jacob W. Beentjes v. Placer County Air Pollution Control District

The Placer County Air Pollution Control District (“the District”) is charged under state law with the responsibility of enforcing state and national air quality standards within its region. The District is part of the larger state and federal scheme to meet air quality standards under the federal Clean Air Act.

Jacob W. Beentjes (“Beentjes”) was a former employee of the District as an air pollution control specialist. This case arose when the District terminated Beentjes after he was diagnosed with a serious pulmonary disease and efforts to accommodate his condition were unsuccessful. Beentjes sued the District alleging that the District’s actions violated Title I of the Americans with Disabilities Act. Beentjes sought damages and injunctive relief.

The District ultimately moved for summary judgment on the ground that, as an arm of the state, it was entitled to sovereign immunity under the Eleventh Amendment. The district court, employing the five-factor test that we adopted in Mitchell v. Los Angeles Community College District, 861 F.2d 198, 201 (9th Cir.1988), and reaffirmed in Belanger v. Madera Unified School District, 963 F.2d 248, 250-51 (9th Cir.1992), determined that the…