Alden v. Maine
Supreme Court of the United States
Argued March 31, 1999 Decided June 23, 1999
Full case name: John H. Alden, et al., Petitioner v. Maine Citations: 527 U.S. 706; 119 S. Ct. 2240; 144 L. Ed. 2d 636; 1999 U.S. LEXIS 4374; 67 U.S.L.W. 4601; 138 Lab. Cas. (CCH) P33,890; 5 Wage & Hour Cas. 2d (BNA) 609; 99 Cal. Daily Op. Service 4913; 99 Daily Journal DAR 6329; 1999 Colo. J. C.A.R. 3654; 12 Fla. L. Weekly Fed. S 467 Prior history: Upon the court's decision in Seminole Tribe v. Florida, the District court dismissed the action and the Court of Appeals affirmed. Petitioners refiled in state court, where their action was dismissed at the trial level on the basis of sovereign immunity and the Maine Supreme Judicial Court affirmed.
Holding
Congress may not abrogate states' sovereign immunity in their own courts.
Court membership
Chief Justice: William Rehnquist Associate Justices: John Paul Stevens, Sandra Day O'Connor, Antonin Scalia, Anthony Kennedy, David Souter, Clarence Thomas, Ruth Bader Ginsburg, Stephen Breyer
Case opinions
Majority by: Kennedy Joined by: Rehnquist, O'Connor, Scalia, Thomas Dissent by: Souter Joined by: Stevens, Ginsberg, Breyer
Laws applied
U.S. Const. art. I; U.S. Const. amend. XI

Alden v. Maine, 527 U.S. 706 (1999)^[1], was a United States Supreme Court case which held that Article One of the U.S. Constitution did not give the United States Congress the power to abrogate the sovereign immunity of the states and thereby allow state citizens to sue their states in the respective state courts. Sovereign immunity is a pre-Constitutional right that is retained by the states and is explicitly protected by the Constitution's Eleventh Amendment. Image File history File links Seal_of_the_United_States_Supreme_Court. ... The Supreme Court of the United States is the highest judicial body in the United States and leads the judicial branch of the United States federal government. ... Holding Congress does not have the power pursuant to the Commerce Clause to abrogate the sovereign immunity afforded to states under the 11th Amendment; the doctrine of Ex parte Young, which allows parties to seek relief against state officials for violations of the Constitution or laws of the United States... William Hubbs Rehnquist (October 1, 1924 – September 3, 2005) was an American lawyer, jurist and political figure, who served as an Associate Justice on the Supreme Court of the United States and later as the Chief Justice of the United States. ... John Paul Stevens (born April 20, 1920) is an American jurist and the senior Associate Justice of the U.S. Supreme Court. ... Sandra Day OConnor (born March 26, 1930) is a former American jurist and politician who served as the first female Associate Justice of the Supreme Court of the United States from 1981 to 2006. ... Antonin Gregory Scalia (born March 11, 1936) is an American jurist on the Supreme Court of the United States who has been a prominent conservative and originalist voice of textualism in statutory interpretation and original meaning in constitutional interpretation. ... For other people of the same name, see Anthony Kennedy (disambiguation). ... David Hackett Souter (born September 17, 1939) has been an Associate Justice of the U.S. Supreme Court since 1990. ... Clarence Thomas (born June 23, 1948) is an American jurist and has been an Associate Justice of the Supreme Court of the United States since 1991. ... Ruth Joan Bader Ginsburg (born March 15, 1933) is a United States Supreme Court Justice. ... Stephen Gerald Breyer (born August 15, 1938) is an American attorney, political figure, and jurist. ... Wikisource has original text related to this article: Article One of the United States Constitution Article One of the United States Constitution establishes the legislative branch of the United States government, known as the Congress, which includes the House of Representatives and the Senate. ... Amendment XI (the Eleventh Amendment) of the United States Constitution was passed by the US Congress on March 4, 1794 and was ratified on February 7, 1795. ... // Case citation is the system used in common law countries such as the United States, England and Wales, Canada, New Zealand, Australia and India to uniquely identify the location of past court cases in special series of books called reporters or law reports. ... 1999 (MCMXCIX) was a common year starting on Friday, and was designated the International Year of Older Persons by the United Nations. ... The Supreme Court Building, Washington, D.C. The Supreme Court Building, Washington, D.C., (large image) The Supreme Court of the United States, located in Washington, D.C., is the highest court (see supreme court) in the United States; that is, it has ultimate judicial authority within the United States... Article One of the United States Constitution establishes the legislative branch of government, Congress, which includes the House of Representatives and the Senate. ... The abrogation doctrine is a doctrine in United States constitutional law which permits the U.S. Congress to allow lawsuits seeking monetary damages against individual U.S. states, so long as this is usually done pursuant to a constitutional limitation on the power of the states. ... Sovereign immunity or crown immunity is a type of immunity that, in common law jurisdictions traces its origins from early English law. ... Amendment XI (the Eleventh Amendment) of the United States Constitution was passed by the US Congress on March 4, 1794 and was ratified on February 7, 1795. ...

Facts

In 1992, the petitioners, a group of probation officers, filed federal suit against the State of Maine alleging violations of the Fair Labor Standards Act of 1938 (FLSA). Their suit was dismissed based upon the Supreme Court’s 1996 ruling in Seminole Tribe v. Florida, in which the Court ruled that states are immune from private suits in federal court and that Congress may not abrogate that immunity. In response, the probation officers filed suit in state court, alleging the state violated FLSA. Both the trial court and state supreme court of Maine ruled the state had immunity from suits brought by individuals in the state courts. The Fair Labor Standards Act of 1938, ch. ... Holding Congress does not have the power pursuant to the Commerce Clause to abrogate the sovereign immunity afforded to states under the 11th Amendment; the doctrine of Ex parte Young, which allows parties to seek relief against state officials for violations of the Constitution or laws of the United States...

Issue

Whether Congress may use its Article One powers to abrogate a state's sovereign immunity from suits in its own courts, thereby allowing citizens to sue a state without the state's consent. Article One of the United States Constitution establishes the legislative branch of government, Congress, which includes the House of Representatives and the Senate. ...

Result

No. In a 5-4 ruling, the Court found that Article I of the United States Constitution does not provide Congress with the ability to subject nonconsenting states to private suits for damages in its own courts. In addition, the Court found that Maine was not a consenting party in the suit, and, therefore, the ruling of the Supreme Court of Maine was upheld. Kennedy held that the Eleventh Amendment to the United States Constitution provides immunity for nonconsenting states from suits filed by citizens of that state or any foreign state, noting that such immunity is often referred to as “Eleventh Amendment Immunity.” Such immunity, he continued, is necessary to maintain the state sovereignty that lies at the heart of federalism.

Having established the immunity granted to states by the Eleventh Amendment, Kennedy turned to the question of whether Congress has the authority, under Article I of the United States Constitution, to subject nonconsenting states to private suits in their own courts. The majority found that Congress has no such authority, because its use would violate the Eleventh Amendment. The majority argued that the Supremacy Clause of the Constitution only applies to pieces of legislation that fit within its design. As such, any law passed by Congress seeking to subject states to such suits would be unconstitutional.

Dissent

Justice Souter's dissent argued that the concept of “sovereign immunity” had been misapplied by the majority. Souter continues by noting that the idea of sovereign immunity was unclear during the period of the Constitution’s ratification. In addition, he argued, the framers would certainly have not expected the idea to remain static over numerous years. David Hackett Souter (born September 17, 1939) has been a US Supreme Court Associate Justice since 1990. ...

In addition, Souter argued that the FSLA was national in scope and, as a result, did not violate the principle of federalism as argued by the majority. Souter also argued that the claim the FSLA was unconstitutional was spurious. Such thinking, he argued, could only be reached based upon the misguided notion of sovereign immunity and notion of federalism the majority had used in reaching its decision.

Analysis

Alden represents a reaffirmation of the Court’s 1996 ruling in Seminole Tribe. The Court’s ruling strikes at two issues simultaneously, federalism and Congressional power. The decision maintains that states have sovereign immunity due to the Eleventh Amendment. This limits Congressional authority to pass legislation which uses state courts as a means of redress, because the majority held that such legislation is unconstitutional, due to the fact it violates the Eleventh Amendment.

External link

• ↑ 527 U.S. 706 (Text of the opinion on Findlaw.com)