Seminole Tribe of Florida V. Florida - Later Developments

Later Developments

In Alden v. Maine (1999), the Court clarified:

overeign immunity derives not from the Eleventh Amendment but from the structure of the original Constitution itself.... Nor can we conclude that the specific Article I powers delegated to Congress necessarily include, by virtue of the Necessary and Proper Clause or otherwise, the incidental authority to subject the States to private suits as a means of achieving objectives otherwise within the scope of the enumerated powers.

In Central Virginia Community College v. Katz (2006), the Court narrowed the scope of its ruling in Seminole Tribe v. Florida. It held the Bankruptcy Clause of Article I abrogated state sovereign immunity.

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