Law School Case Brief
Alden v. Maine - 527 U.S. 706, 119 S. Ct. 2240 (1999)
The Eleventh Amendment makes explicit reference to the states' immunity from suits commenced or prosecuted against one of the United States by citizens of another state, or by citizens or subjects of any foreign state.
After the Supreme Court of the United States decided that Congress lacked power under Article I to abrogate the States' sovereign immunity in federal court, a federal district court dismissed a Fair Labor Standards Act of 1938 (FLSA) suit filed by petitioners John Alden and others against their employer, respondent State of Maine. Subsequently, petitioners filed the same action in state court. Although the FLSA authorized private actions against states in their own courts, the trial court dismissed the suit on the ground of sovereign immunity. The Maine Supreme Judicial Court affirmed.
Did Congress have powers under Article I of the Constitution to subject non-consenting states to private suits for damages in state courts?
The Court affirmed the dismissal. The Court reasoned that the powers delegated to Congress under U.S. Const. art. I did not include the power to subject nonconsenting states to private suits for damages in state courts and that respondent did not consent to suits for overtime pay and liquidated damages under the FLSA.
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