Alden v. Maine
| Alden v. Maine | |
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| Argued March 31, 1999 Decided June 23, 1999 |
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| Full case name | Alden et al. v. Maine |
| Citations | 527 U.S. 706 (more)
119 S. Ct. 2240
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| Prior history | Certiorari to the Supreme Judicial Court of Maine |
| Holding | |
| 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. | |
| Court membership | |
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| Case opinions | |
| Majority | Kennedy, joined by Rehnquist, O'Connor, Scalia, Thomas |
| Dissent | Souter, joined by Stevens, Ginsburg, Breyer |
| Laws applied | |
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U.S. Const. arts. I, § 8, III, § 2 U.S. Const. amend. XI |
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Alden v. Maine, 527 U.S. 706 (1999), was a decision by the Supreme Court of the United States about whether the United States 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 in state court without the state's consent.
In 1992, probation officers employed by the State of Maine filed a suit against their employer in United States District Court for the District of Maine. The probation officers alleged violations of the overtime provisions laid out in the Fair Labor Standards Act (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 gives the states sovereign immunity 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.
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. However, according to Alden v. Maine, "sovereign immunity derives not from the Eleventh Amendment but from the federal structure of the original Constitution itself."
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