Alden v. Maine
Encyclopedia
Alden v. Maine, 527 U.S. 706
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...

 (1999) was a decision by the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...

 about whether the United States Congress
United States Congress
The United States Congress is the bicameral legislature of the federal government of the United States, consisting of the Senate and the House of Representatives. The Congress meets in the United States Capitol in Washington, D.C....

 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.

Background

In 1992, probation officers employed by the State of Maine
Maine
Maine is a state in the New England region of the northeastern United States, bordered by the Atlantic Ocean to the east and south, New Hampshire to the west, and the Canadian provinces of Quebec to the northwest and New Brunswick to the northeast. Maine is both the northernmost and easternmost...

 filed a suit against their employer in United States District Court for the District of Maine
United States District Court for the District of Maine
The U.S. District Court for the District of Maine is the U.S. district court for the state of Maine. The District of Maine was one of the original thirteen district courts established by the Judiciary Act of 1789, even though Maine was not a separate state from Massachusetts until 1820...

. The probation officers alleged violations of the overtime provisions laid out in the Fair Labor Standards Act
Fair Labor Standards Act
The Fair Labor Standards Act of 1938 is a federal statute of the United States. The FLSA established a national minimum wage, guaranteed 'time-and-a-half' for overtime in certain jobs, and prohibited most employment of minors in "oppressive child labor," a term that is defined in the statute...

 (FLSA), a federal statute, and requested liquidated damages and compensation. The federal court dismissed the suit, stating that the Eleventh Amendment to the United States Constitution
Eleventh Amendment to the United States Constitution
The Eleventh Amendment to the United States Constitution, which was passed by the Congress on March 4, 1794, and was ratified on February 7, 1795, deals with each state's sovereign immunity. This amendment was adopted in order to overrule the U.S. Supreme Court's decision in Chisholm v...

 gives the states sovereign immunity
Sovereign immunity
Sovereign immunity, or crown immunity, is a legal doctrine by which the sovereign or state cannot commit a legal wrong and is immune from civil suit or criminal prosecution....

 from suit in federal court. After the dismissal, the probation officers filed the same action in Maine state court. The state court also dismissed the case based on sovereign immunity. The case was then appealed to the Maine appellate courts, and then to the Supreme Court of the United States.

The Opinion of the Court

In a 5-4 ruling, the Court concluded 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 held that Maine was not a consenting party in the suit, and, therefore, the ruling of the Supreme Court of Maine was upheld. Writing for the Court, Justice Anthony Kennedy stated that the United States Constitution provides immunity for nonconsenting states from suits filed by citizens of that state or citizens of any other state, noting that such immunity is often referred to as "Eleventh Amendment Immunity". Such immunity, the Court continued, is necessary to maintain the state sovereignty that lies at the heart of federalism
Federalism
Federalism is a political concept in which a group of members are bound together by covenant with a governing representative head. The term "federalism" is also used to describe a system of the government in which sovereignty is constitutionally divided between a central governing authority and...

. However, according to Alden v. Maine, "sovereign immunity derives not from the Eleventh Amendment but from the federal structure of the original Constitution itself."

After discussing the Eleventh Amendment, the Court 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 ruled 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.


However, Congress may abrogate sovereign immunity when the suit is to enforce a statute protecting Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...

 rights: "We have held also that in adopting the Fourteenth Amendment, the people required the States to surrender a portion of the sovereignty that had been preserved...Congress may authorize private suits against nonconsenting States pursuant to its §5 enforcement power...When Congress enacts appropriate legislation to enforce this Amendment, see City of Boerne v. Flores, 521 U.S. 507 (1997), federal interests are paramount"

The majority stated that the Supremacy Clause of the Constitution only applies to pieces of legislation that fit within its design. Therefore, any law passed by Congress pursuant to Article I that seeks to subject states to suit would violate the original, unamended Constitution. However, states do not have sovereign immunity if Congress is enforcing the Fourteenth Amendment. See, for example, Fitzpatrick v. Bitzer
Fitzpatrick v. Bitzer
Fitzpatrick v. Bitzer, 427 U.S. 445 , was a United States Supreme Court decision that determined that the U.S. Congress has the power to abrogate the Eleventh Amendment sovereign immunity of the states, if this is done pursuant to its Fourteenth Amendment power to enforce upon the states the...

(1976).

Dissent

Justice David Souter
David Souter
David Hackett Souter is a former Associate Justice of the Supreme Court of the United States. He served from 1990 until his retirement on June 29, 2009. Appointed by President George H. W. Bush to fill the seat vacated by William J...

'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
Founding Fathers of the United States
The Founding Fathers of the United States of America were political leaders and statesmen who participated in the American Revolution by signing the United States Declaration of Independence, taking part in the American Revolutionary War, establishing the United States Constitution, or by some...

 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.

Analysis

Alden represents an extension of the Court’s 1996 ruling in Seminole Tribe v. Florida
Seminole Tribe v. Florida
Seminole Tribe of Florida v. Florida, 517 U.S. 44 , 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 that is further protected under the Eleventh Amendment...

, which had held that Congress cannot use its powers under Article I of the Constitution to subject unconsenting states to suit in federal court. Alden holds that Congress cannot use its Article I powers to subject unconsenting states to suit in state court. Later, in Central Virginia Community College v. Katz
Central Virginia Community College v. Katz
Central Virginia Community College v. Katz, 546 U.S. 356 , is a United States Supreme Court case holding that the Bankruptcy Clause of the Constitution abrogates state sovereign immunity...

(2006), the Court would narrow the scope of its previous sovereign immunity rulings, and hold that Congress could use the Bankruptcy Clause of Article I to abrogate state sovereign immunity.

See also

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