In Dellmuth v. Muth, the U.S. Supreme Court ruled in 1988 that individual state officials cannot be sued for damages under the Education of All Handicapped Children Act (EAHCA), now known as Individuals with Disabilities Education Act (IDEA). The case was brought forward by parents of a disabled child who alleged that Pennsylvania's Secretary of Education had violated their child's rights under EAHCA by failing to provide appropriate educational services. However, the court held in a 5-4 decision that Congress did not intend to abrogate states' Eleventh Amendment immunity when it enacted EAHCA and therefore, state officials could not be personally liable for monetary damages under this act.

In the dissenting opinion for Dellmuth v. Muth, Justice White argued that Congress had clearly intended to abrogate state sovereign immunity in passing the Education of All Handicapped Children Act (EAHCA). He pointed out that the majority's decision was based on a technicality - namely, whether or not Congress had explicitly stated its intention to do so in the statutory text. However, he contended that such explicitness should not be necessary when it is clear from both legislative history and context what Congress' intent was. Furthermore, he noted that this ruling could have far-reaching implications for other federal statutes where congressional intent to abrogate may be implied rather than expressly stated. In essence, Justice White disagreed with the majority's strict interpretation of Congressional power under Section 5 of Fourteenth Amendment and believed it undermined important federal protections against state infringement on individual rights.