Seminole Tribe of Florida V. Florida - Result

Result

The Court, in an opinion by Chief Justice William Rehnquist, struck down this abrogation as unconstitutional, and further held that the doctrine of Ex parte Young does not apply in this situation.

The Court began by repudiating the precedential value of Union Gas, noting that there was no single majority rationale, and characterizing it as a major departure from the 19th century case of Hans v. Louisiana, 134 U.S. 1 (1890), which had established the modern doctrine of sovereign immunity. The Court suggested that allowing Congress to abrogate sovereign immunity improperly expanded the jurisdiction of the federal courts beyond what Article Three of the U.S. Constitution permitted. The Eleventh Amendment, it contended, had further protected the states' sovereign immunity; the Fourteenth Amendment placed limitations on the Eleventh Amendment, but only with respect to the rights guaranteed in the Fourteenth Amendment.

The Court also found that the doctrine of Ex parte Young did not apply, invoking the rationale of an earlier case, Schweiker v. Chilicky, 487 U.S. 412 (1988), for the proposition that where Congress had provided a remedial scheme, the Courts would not imply the existence of additional remedies.

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