The Eleventh Amendment and State Immunity under ederal Courts
The Eleventh Amendment and State Immunity under Federal Courts
1. Overview of the Eleventh Amendment
The Eleventh Amendment to the U.S. Constitution, ratified in 1795, states:
"The Judicial power of the United States shall not be construed to extend to any suit in law or equity, commenced or prosecuted against one of the United States by Citizens of another State, or by Citizens or Subjects of any Foreign State."
Key point: The amendment limits the ability of federal courts to hear cases brought against a state by citizens of another state or foreign citizens.
2. State Sovereign Immunity
The Eleventh Amendment is widely understood as codifying the principle of state sovereign immunity, which means:
States cannot be sued in federal court by private individuals without the state's consent.
This immunity protects states from certain lawsuits, preserving their sovereignty.
3. Scope of the Eleventh Amendment
Originally, the Eleventh Amendment was interpreted to bar only suits against a state by citizens of another state or foreign citizens, but not by citizens of the same state.
However, modern interpretation has expanded sovereign immunity to include suits by a state’s own citizens.
4. Key Supreme Court Cases
a) Hans v. Louisiana, 134 U.S. 1 (1890)
Facts: A citizen of Louisiana sued the state in federal court over a bond issue.
Holding: The Supreme Court ruled that states enjoy sovereign immunity from suits brought by their own citizens in federal court, even though the Eleventh Amendment textually only mentions suits by citizens of other states.
Significance: This case established the doctrine that state sovereign immunity applies broadly to prevent private suits against states in federal court, regardless of the plaintiff’s citizenship.
b) Ex parte Young, 209 U.S. 123 (1908)
Facts: Plaintiffs sought to stop the state attorney general from enforcing an allegedly unconstitutional law.
Holding: The Court allowed lawsuits against state officials (not the state itself) in their official capacity for injunctive relief to stop ongoing violations of federal law or the Constitution.
Significance: This exception to sovereign immunity enables federal courts to grant injunctive relief against state officials, but not monetary damages against the state.
c) Seminole Tribe of Florida v. Florida, 517 U.S. 44 (1996)
Facts: The Seminole Tribe sued Florida to enforce a provision of the Indian Gaming Regulatory Act.
Holding: The Court held that Congress cannot abrogate state sovereign immunity under its Article I powers (such as the Commerce Clause).
Significance: Congress’s power to override state immunity is limited; Congress can only abrogate immunity when acting under Section 5 of the Fourteenth Amendment or where the Constitution explicitly allows it.
d) Alden v. Maine, 527 U.S. 706 (1999)
Facts: State employees sued Maine for violating the Fair Labor Standards Act in state court.
Holding: The Court ruled that states retain sovereign immunity from private suits in their own courts as well.
Significance: Sovereign immunity is a constitutional principle protecting states not just from federal court suits but also from suits in their own courts unless waived.
e) Fitzpatrick v. Bitzer, 427 U.S. 445 (1976)
Facts: Employees sued the state for discrimination under Title VII of the Civil Rights Act.
Holding: The Court held that Congress can abrogate state sovereign immunity under Section 5 of the Fourteenth Amendment.
Significance: Congress may waive sovereign immunity when legislating under the Fourteenth Amendment to enforce civil rights protections.
5. Principles Derived
Sovereign Immunity Bars Suits Against States Without Consent: States cannot be sued in federal court by private parties unless the state consents or Congress validly abrogates immunity.
Eleventh Amendment Applies Even to Citizens Suing Their Own State: Hans v. Louisiana broadened the Amendment’s reach.
Ex parte Young Exception: Federal courts can enjoin state officials to prevent ongoing constitutional violations.
Congressional Abrogation is Limited: Only under certain constitutional provisions, like Section 5 of the Fourteenth Amendment, can Congress override immunity.
6. Exceptions and Waivers
Waiver by the State: A state may waive its immunity explicitly or implicitly (e.g., by voluntarily participating in federal programs that condition benefits on waiver).
Abrogation by Congress: Only valid if Congress acts under a constitutional provision authorizing it (e.g., Fourteenth Amendment).
Ex parte Young: Lawsuits seeking injunctive relief against state officers for ongoing violations.
7. Practical Impact
Individuals suing states for damages in federal court usually cannot proceed unless immunity is waived or abrogated.
Injunctive relief against state officials remains a vital tool for civil rights enforcement.
State immunity doctrine preserves the balance of federalism by protecting state sovereignty from federal judicial overreach.
Summary Table
| Case | Holding | Key Point |
|---|---|---|
| Hans v. Louisiana (1890) | States immune from suits by own citizens | Broad sovereign immunity under Eleventh Amendment |
| Ex parte Young (1908) | Lawsuits against state officials allowed for injunctions | Exception for ongoing violations of federal law |
| Seminole Tribe v. Florida (1996) | Congress can’t abrogate immunity under Article I powers | Limits on congressional override of immunity |
| Alden v. Maine (1999) | Sovereign immunity applies in state courts | Extends immunity beyond federal courts |
| Fitzpatrick v. Bitzer (1976) | Congress can abrogate immunity under Fourteenth Amendment | Congressional power to enforce civil rights |
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