Seminole Tribe v. Florida
| Seminole Tribe of Florida v. Florida | |
|---|---|
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| Argued October 11, 1995 Decided March 27, 1996 |
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| Full case name | Seminole Tribe of Florida, Petitioner v. State of Florida, et al. |
| Citations | 517 U.S. 44 (more)
116 S. Ct. 1114; 134 L. Ed. 2d 252; 1996 U.S. LEXIS 2165; 64 U.S.L.W. 4167; 67 Empl. Prac. Dec. (CCH) P43,952; 42 ERC (BNA) 1289; 34 Collier Bankr. Cas. 2d (MB) 1199; 96 Cal. Daily Op. Service 2125; 96 Daily Journal DAR 3499; 9 Fla. L. Weekly Fed. S 484
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| Prior history | Motion to dismiss denied, 801 F.Supp. 655 (S.D. Fla. 1992); reversed, 11 F. 3d 1016 (11th Cir., 1994) |
| Holding | |
| Congress does not have the power under the Commerce Clause to abrogate the sovereign immunity afforded to states under the 11th Amendment; the doctrine of Ex parte Young, which allows parties to seek relief against state officials for violations of the Constitution or laws of the United States, does not apply where Congress has already created what it deems a sufficient remedy. | |
| Court membership | |
| Case opinions | |
| Majority | Rehnquist, joined by O'Connor, Scalia, Kennedy, Thomas |
| Dissent | Stevens |
| Dissent | Souter, joined by Ginsburg, Breyer |
| Laws applied | |
| U.S. Const. amend. XI | |
Seminole Tribe of Florida v. Florida, 517 U.S. 44 (1996), 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. Such abrogation is permitted where it is necessary to enforce the rights of citizens guaranteed under the Fourteenth Amendment as per Fitzpatrick v. Bitzer 427 U.S. 445 (1976). The case also held that the doctrine of Ex parte Young, 209 U.S. 123 (1908), which allows state officials to be sued in their official capacity for prospective injunctive relief, was inapplicable under these circumstances, because any remedy was limited to the one that Congress had provided.
In 1988 Congress passed the Indian Gaming Regulatory Act, a statute requiring the states to negotiate with Indian tribes to create compacts governing Indian Gaming. The statute provided that if a state failed to enter into such negotiations, or to negotiate in good faith, the Tribes could sue the state in federal court in order to compel the states to negotiate. If the states still refused, the statute provided that the matter would ultimately be referred to the Secretary of the Interior. Congress had asserted its power under the part of the Commerce Clause relating to commerce with Indians to pass such a statute, abrogating the immunity of states pursuant to its express powers.
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