Seminole Tribe of Florida v. Florida

Facts

The Petitioner sued the Respondents alleging that Respondents had refused to enter into any negotiation for inclusion of gaming activities in a tribal state compact, thereby violating the requirement of good faith negotiation contained in the Act. Respondents moved to dismiss the complaint, arguing that the suit violated the State’s sovereign immunity from suit in a federal court. The District Court denied Respondents motion. The Court of Appeals reversed the District Courts decision, holding that the Eleventh Amendment of the Constitution barred the Petitioner’s suit against the Respondents. The Supreme Court of the United States (Supreme Court) granted certiorari. In deciding the case the Supreme Court asked whether (1) Congress had unequivocally expressed its intent to abrogate the immunity and (2) whether Congress had acted pursuant to a valid exercise of power. The Supreme Court determined that Congress did unequivocally intend to abrogate the State’s sovereign immunity f rom a clear legislative statement. In the next step of its analysis, the Supreme Court inquired whether the Act in question was passed pursuant to a constitutionals provision granting Congress the power to abrogate. The Supreme Court acknowledged that they had only found authority to abrogate under very few provisions of the Constitution. One of which being the Enforcement Clause of the Fourteenth Amendment of the Constitution. The Supreme Court found in Fitzpatrick v. Bitzer, that Congress can abrogate State’s sovereign immunity pursuant to the Enforcement Clause of the Fourteenth Amendment of the Constitution. The Supreme Court, in the instant case, then overruled one of its previous rulings in Pennsylvania v. Union Gas Co., recognizing it had reached that decision without an express rationale for allowing Congress to abrogate a State’s sovereign immunity. In overruling Union Gas, the Supreme Court reached one of its holdings that the Eleventh Amendment of the Constitution prevents congressional authorization of suits by private parties against unconsenting States. In deciding the second issue, the Supreme Court determined that a suit could not be brought against the State Governor based on Ex Parte Young as the statute provided remedial measures to enforce the statute. Thus, the case was not appropriate for a judicial ruling.