Hans v. Louisiana

134 U.S. 1, 10 S. Ct. 504 (1890)

 

RULE:

U.S. Const. amend. XI is interpreted to hold that a state cannot be sued by a citizen of another state, or of a foreign state, on the mere ground that the case is one arising under the United States Constitution or laws.

FACTS:

Under the provisions of an act of the legislature, the State of Louisiana issued bonds that were known as the "consolidated bonds of the State of Louisiana”.  Petitioner Hans brought a suit in the Circuit Court of the United States against the Defendant State in order to recover the amount of certain coupons annexed to the aforementioned bonds; the coupons sued on were for interest which accrued. The State of Louisiana argued that the federal court could not exert jurisdiction over the case because the suit was barred by U.S. Const. amend. XI. According to the Defendant, it had sovereign immunity from Hans’ complaint. The Circuit Court of the United States for the Eastern District of Louisiana ruled in favor of the Defendant. Subsequently, Hans sought a review of the court’s decision.

ISSUE:

Can the State of Louisiana be sued in federal court by one of its own citizens upon a suggestion that the case arose under the Constitution or laws of the United States?

ANSWER:

No.

CONCLUSION:

The Court held that a citizen could not sue a state unless the state consented to jurisdiction. The Court based this decision on a historical analysis of sovereignty, as well as an examination of the purpose behind U.S. Const. amend. XI. In the case at bar, the Court held that the State had not consented to jurisdiction; therefore, the Court could not exercise jurisdiction over the matter even if there were legal grounds for the underlying suit. 

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