Ex Parte Young
Citation: 209 U.S. 123 (1908)
Facts
Minnesota enacted railroad rate regulations with severe penalties. Shareholders sued Edward Young, the Attorney General of Minnesota, seeking to enjoin enforcement of the rates as unconstitutional. Young argued that as a state officer he was immune from suit in federal court under the Eleventh Amendment.
Issue
Does the Eleventh Amendment bar a federal court from enjoining a state attorney general from enforcing an allegedly unconstitutional state law?
Holding
No. The Supreme Court held that a state official who acts in violation of the Constitution is stripped of state authority and is therefore not acting as the state — so the Eleventh Amendment does not bar the suit. Federal courts may issue prospective injunctive relief against state officials.
Rule
The Ex Parte Young fiction: when a state official threatens to enforce a law alleged to be unconstitutional, a federal court may enjoin that official in their official capacity for prospective relief without violating the Eleventh Amendment, because such unconstitutional conduct is not protected state action.
Significance
Ex Parte Young is essential to federal civil rights litigation. Without it, states could hide unconstitutional conduct behind sovereign immunity. It creates the critical exception allowing prospective injunctions against state officials, though it does not allow retrospective money damages from the state treasury.