Analysis
Alden represents an extension of the Court’s 1996 ruling in Seminole Tribe v. Florida, which had held that Congress cannot use its powers under Article I of the Constitution to subject unconsenting states to suit in federal court. Alden holds that Congress cannot use its Article I powers to subject unconsenting states to suit in state court. Later, in Central Virginia Community College v. Katz (2006), the Court would narrow the scope of its previous sovereign immunity rulings, and hold that Congress could use the Bankruptcy Clause of Article I to abrogate state sovereign immunity.
Read more about this topic: Alden V. Maine
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