Alden v. Maine
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| Alden v. Maine | |||||||||||
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| Argued March 31, 1999 Decided June 23, 1999 |
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| 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 |
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| Case opinions | |||||||||||
| Majority by: Kennedy Joined by: Rehnquist, O'Connor, Scalia, Thomas Dissent by: Souter Joined by: Stevens, Ginsberg, Breyer |
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| Laws applied | |||||||||||
| U.S. Const. art. I; U.S. Const. amend. XI | |||||||||||
Alden v. Maine, 527 U.S. 706 (1999), 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. The Constitution's Eleventh Amendment also addresses sovereign immunity, and states that citizens of one state cannot sue another, different state.
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[edit] 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.
[edit] 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.
[edit] 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. Justice Kennedy held that 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. However, according to the Alden Court, "sovereign immunity derives not from the Eleventh Amendment but from the structure of the original Constitution itself."
After discussing 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, under the original unamended Constitution, to abrogate states' sovereign immunity:
- Nor can we conclude that the specific Article I powers delegated to Congress necessarily include, by virtue of the Necessary and Proper Clause or otherwise, the incidental authority to subject the States to private suits as a means of achieving objectives otherwise within the scope of the enumerated powers.
The majority stated 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 violate the original, unamended Constitution. However, states do not have sovereign immunity if Congress is enforcing the Fourteenth Amendment. See, e.g., Fitzpatrick v. Bitzer, 427 U.S. 445 (1976).
[edit] Dissent
Justice Souter's dissent argued that the concept of “sovereign immunity” had been misapplied by the majority. Souter continued 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.
In addition, Souter argued that the FLSA 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 FLSA 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.
[edit] 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. 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. In Central Virginia Community College v. Katz (2006), the Court narrowed the scope of its previous sovereign immunity rulings, and held that the Bankruptcy Clause of Article I abrogated state sovereign immunity.
