In the 1983 case of Pennhurst State School and Hospital v. Halderman, the U.S. Supreme Court ruled that federal courts could not order states to follow state laws under the Eleventh Amendment. The case arose when Terri Lee Halderman, a resident at Pennhurst State School and Hospital in Pennsylvania - an institution for individuals with intellectual and physical disabilities - filed a lawsuit claiming abuse and neglect by staff members violated her constitutional rights as well as state law. Initially, lower courts decided in favor of Halderman, ordering reforms based on both federal civil rights law (the Developmentally Disabled Assistance Bill of Rights Act) and Pennsylvania's Mental Health/Mental Retardation Act. However, upon reaching the Supreme Court it was determined that while federal courts could enforce compliance with federal laws against states under Section 1983 claims; they did not have authority to mandate adherence to state laws due to sovereign immunity provided by the Eleventh Amendment.

In the dissenting opinion for Pennhurst State School and Hospital v. Halderman, Justice William Brennan disagreed with the majority's interpretation of the Developmentally Disabled Assistance and Bill of Rights Act. He argued that Congress intended to create enforceable rights under this act, contrary to what the majority believed. The language used in Section 6010 was mandatory rather than hortatory or advisory as suggested by Chief Justice Burger’s majority opinion. Furthermore, he contended that if Congress had not meant for these standards to be legally binding, they would have simply recommended them instead of requiring states to provide "appropriate treatment" in order "to assure" certain outcomes for disabled individuals. Moreover, Brennan pointed out that other sections within this law were clearly intended by Congress to be enforceable through lawsuits brought by aggrieved persons - a fact which supported his view on Section 6010's intent too.