Supreme Court rules that a lawsuit against a state by one of its own citizens cannot be heard in federal court. A treaty between the United States and Spain sets the boundary between the U. In , Congress accepts Texas as a state if it meets certain conditions, including the designation of specific boundary lines.
The Texas legislature and a federal land commission disagree over approximately 1. Texas argues that the Eleventh Amendment bars the U. In United States v. Texas , the Supreme Court holds that the deferral courts have jurisdiction in cases in which the U. The Minnesota legislature passes laws that reduce the rates that railroad companies can charge to carry passengers and cargo. Stockholders of the railroads file nine lawsuits in federal court against Minnesota officials, challenging the new rate schedules.
In one of these cases, Ex Parte Young , the Supreme Court holds that it is proper to hear the case in federal court because it involves a federal question: whether the high fines deny the railroad stockholders due process of law for taking property without a fair procedure in place. In such circumstances, the state is not immune from suit. In the early s, a number of Mississippi citizens purchase bonds from their home state. The heirs of the original bondholders, who are unable to collect on the bonds, give them, as a gift, to the Principality of Monaco.
Although worthless to the Mississippi residents, they think that Monaco, as a foreign country, might be able to go to federal court to collect on the long overdue debt.
Mississippi refuses to pay and argues that under the Eleventh Amendment the federal courts have no jurisdiction to hear the case. In Principality of Monaco v. Mississippi , the Court finds that the doctrine of sovereign immunity protects Mississippi from suits by foreign countries unless the state specifically consents to such a suit.
No such consent is given. A group of people eligible for a welfare program administered by both the federal and state governments ask a federal court to order Illinois to comply with federal time limits in handing out grants. The lower courts ordered Illinois to comply with the federal time limits and to pay out grants that have been wrongfully withheld from recipients. Illinois appeals, claiming that its sovereign immunity under the Eleventh Amendment means that the federal courts cannot order it to pay the grants.
In , the Executive Council of Georgia authorized the purchase of needed supplies from a South Carolina merchant and businessman. Georgia said that it was a sovereign state and not subject to the authority of the federal courts unless it decided to be sued, and thus refused to appear. The Chisholm decision came about during an ongoing popular constitutional movement to amend the Constitution in order to secure the understanding, as promised by the Federalists, that federal courts would respect the retained rights of the people in the states and treat states as retaining their sovereign immunity.
Soon after the Chisholm decision, Massachusetts was sued and John Hancock, in his final public act, summarized the outrage:. In Chisholm v. Georgia , the court held that the Constitution permitted a lawsuit in federal court against a state by a citizen of another state.
States with Revolutionary War debts did not want to be vulnerable to lawsuits from creditors. They protested, prompting Congress to pass a resolution to amend the Constitution to bar suits against states.
This was important because the author of the Amendment Senator Strong of Massachusetts undoubtedly meant it to bar the pending case of Vassall v. Massachusetts from proceeding in federal court—even though the plaintiff was seeking to enforce the Treaty of Peace. In sum, because the Eleventh Amendment made sense as written when adopted, the Supreme Court should follow the text of the Amendment today and reject calls to expand or contract its specific terms in favor of broader constitutional values.
For further elaboration, see Bradford R. Some forms of jurisdiction authorized by Article III of the Constitution are based on the parties; others are based on the subject matter. The Eleventh Amendment is best read as a specific repeal of a party-based grant of jurisdiction originally found in Article III.
If the Eleventh Amendment were intended to protect the states from all liability in suits by private parties as Hans v. Louisiana suggested in , it is poorly drafted to do so: there would be no need to recite that citizens of other states, and of foreign states, are the parties barred.
Georgia , and under which all then-pending suits against states including Massachusetts appear to have been brought. Supreme Court decisions closer in time to its adoption treated the Amendment as narrow in scope. For example, in Osborn v. Bank of the United States , the Court explained that the Eleventh Amendment should apply only where the state itself is named as a party; it did not constrain jurisdiction over state officers in an action to recover money due the Bank of the United States.
When the Constitution and the Eleventh Amendment were adopted, there was uncertainty—reflecting a set of questions not fully answered—about the scope of the judicial power, especially over cases arising under federal law. Disagreement over whether states were suable under Article III at the time of ratification was noted in our joint statement; for example, Edmund Randolph, a member of the Committee of Detail that played a key role in drafting the Constitution and a supporter of ratification, argued in the Virginia ratifying convention that states could and should be subject to suit on their obligations.
In the drafting of the Eleventh Amendment, broader and narrower proposals were rejected in Congress, leaving room for scholars to disagree about their import. An important structural principle is that judicial power must be coextensive with the legislative power—expressed in The Federalist No.
Although arising from a dispute between private parties, Martin v. It is a mistake that the constitution was not designed to operate upon states, in their corporate capacities. It is crowded with provisions which restrain or annul the sovereignty of the states. The courts of the United States can. Surely the exercise of the same right over judicial tribunals is not a. Not only did the Constitution impose obligations and prohibitions on states, it also gave the Supreme Court jurisdiction to resolve controversies between two or more States.
Under Eleventh Amendment doctrine there is no immunity from suits by the United States, or by sister states. Coercive judicial power in such cases was plainly contemplated. Although the Convention did not adopt proposals to authorize use of armed force specifically against states, this does not mean that it abandoned national power to impose legal requirements on the states. Rather, the Constitution added to the powers of the national government the powers to regulate and tax individuals directly—because doing so would work better than trying to compel the states to do so.
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