Summary of Alden v. Maine
Citation: 527 U.S. 706
Relevant Facts: In 1992, a group of probation officers sued the State of Maine (their employer), claiming that it had violated overtime provisions of the 1938 Fair Labor Standards Act. The lawsuit came on the heels of the 1996 Seminole Tribe v. Florida case in which the Court held that States are immune from private lawsuits in federal court, and that Congress lacked the power to abrogate the sovereign immunity of states. The probation officers’ suit was dismissed in federal district court. Alden and his fellow petitioners sued Maine again but in state rather than federal court. The state trial court and supreme court sided with Maine and held that the State had sovereign immunity and could not be sued by private parties in court. The matter was appealed and ultimately heard by the United States Supreme Court.
Issues: The legal question presented was whether Congress can use its Article I powers to abrogate a state’s sovereign immunity from private suits in its own trial courts?
Holding: The Supreme Court held that it could not.
Reasoning: Although sharply divided, the Supreme Court reasoned that Congress does not have the authority via Article I to abrogate states’ sovereign immunity. The Court reasoned that the text and history/intent of the 11th Amendment made clear that states are to be immune from suits in their own courts. Additionally, the Court reasoned that the original understanding of the power afforded by the amendment was to confirm and ensure that states retain a good deal of their sovereignty even though there would be matters in which the federal government’s power would supercede based upon its enumerated powers.
Dissent: Associate Justice Souter dissented, arguing that the majority has inappropriately applied the concept of sovereign immunity to the case. He further argued that contrary to the Court’s rationale that the intent of the concept and amendment was clear, he indicated that it was in fact unclear, and that this is confirmed by the historical record. Since the FLSA was national in scope, it did not violate the principle of federalism as contended by the majority, but rather could be assessed along with it, towards the same end.