In Quern v. Mandley, the Supreme Court of the United States ruled in favor of Illinois' Department of Public Aid (DPA), concluding that a federal court could not order state officials to send out notices informing welfare recipients about their rights under a previous ruling by the same court. The case arose after DPA reduced benefits for certain recipients without providing prior notice or hearing, which was found to be unconstitutional in an earlier decision. However, when plaintiffs sought enforcement including mailing notifications explaining this violation and how it would be corrected, DPA objected on grounds that such action exceeded judicial authority as per Eleventh Amendment immunity protections for states against suits seeking retroactive monetary relief. The Supreme Court agreed with DPA's argument stating that while courts can enjoin state officials from future violations of federal law they cannot mandate actions akin to awarding damages payable out of the state treasury.

In the dissenting opinion for Quern v. Mandley, Justice Brennan disagreed with the majority's interpretation of Section 1983 and its legislative history. He argued that Congress intended to provide a broad remedy for constitutional violations by state officials when it enacted this law in 1871, including violations of federal statutory rights as well as constitutional rights. In his view, the majority's decision undermined this purpose by limiting plaintiffs' ability to sue state officials under Section 1983 for violating their federally protected welfare rights. Furthermore, he contended that there was no evidence from the legislative history suggesting Congress wanted to exclude such claims from Section 1983’s scope or leave them solely to be addressed through habeas corpus proceedings or other specific remedies provided in individual statutes.