The Sixth Circuit ruled this week that the Hamilton County Department of Job and Family Services was not entitled to 11th Amendment immunity from civil rights claims. The Court applied the four factors deemed applicable to determining whether the Agency is an "arm" of the state for 11th Amendment purposes. It emphasized in particular the cardinal test of payment responsibility: It concluded that the State was not obligated to pay any judgment entered against the County Department, even though it was likely to reimburse the Agency as a cost of administering its Medicaid program. Therefore, the 11th Amendment did not confer immunity. The case is Lowe v. Hamilton County Dep't of Job & Family Services.