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| SOVEREIGN IMMUNITY WORKS FOR STATES IN FMLA CASES, BUT NOT IN TITLE VII CASES |
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| On the same day, the Eighth Circuit held that Congress clearly intended States to be covered by Title VII and the Eleventh Circuit found that sovereign immunity protects States from FMLA claims. Both Courts looked to legislative intent to determine if sovereign immunity applied. |
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| (Okruhlik v. University Of Ark., 8th Circuit and Lizzi v. Alexander, 4th Cir.) |
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