This one brings together a lot of things we have discussed or will discuss. Plaintiffs sued the head of the state judicial council (the body that trains state-court judges) seeking to alter how it trains judges on matters of parental rights (they argue that state courts are too quick to strip parents of their rights, in violation of due process, which is probably true).
Point One of the opinion shows the move among policymakers, Monell, and the 11th Amendment. The head of the council (sued in her official capacity) is a policymaker, but the council is an arm of the state, thus not a § 1983 person (it gets that right).
Point Two shows the limits of EpY, namely that it runs against the executive rather than the court. Thus an injunction altering judicial training is, in effect, an injunction requiring judges to decide cases a certain way, which exceeds the scope of the EpY cause of action. That last point is interesting and perhaps contestable--would plaintiffs gain meaningful relief from an injunction altering training even if it does not affect any state court action? Consider this when we turn to remedies and standing in Chapter 9.
