The plaintiff in that case was an employee who alleged that the Michigan Department of State Police and the Michigan Director of State Police, in his official capacity, had violated 42 U.S.C. 1983 when they denied the plaintiff a promotion for an improper reason. The Michigan Court of Appeals ultimately ruled that a State was not a person under 42 U.S.C. 1983. On certiorari, the U.S. Supreme Court held that neither a State nor a State official acting in an "official capacity" is a "person." The "Will" Court specifically stated that its holding would not apply to 42 U.S.C. 1983 injunctive actions against State officials; however, the Court did not discuss whether the general rule barring damage actions against State officials applied when the requested injunctive relief would have a major financial impact on the State. "Will" is likely to shift the weight of 42 U.S.C. 1983 damages litigation from the Federal courts to State courts. It is doubtful whether State courts will be as open to inmate litigation as Federal district courts have been. 11 footnotes.