Lincoln County v. Luning
Citation and Court
133 U.S. 529 (1890) — Supreme Court of the United States
Facts
Luning held bonds issued by Lincoln County, Nevada. When the county defaulted, he brought suit in federal circuit court to compel payment. Lincoln County invoked the Eleventh Amendment as a bar to the federal suit.
Issue
Whether the Eleventh Amendment’s bar on suits against states extends to suits against counties and other local governmental units.
Holding
No. The Eleventh Amendment does not bar suits in federal court against counties, municipalities, or other local subdivisions of a state; it protects only the state itself.
Rule / Doctrine
The Eleventh Amendment’s sovereign immunity applies to states as sovereign entities. Counties and municipalities are creatures of state law and not sovereigns themselves; they may be sued in federal court without implicating the Eleventh Amendment.
Significance
Lincoln County is the foundational case establishing that local governments — counties, cities, school districts — are not protected by state sovereign immunity under the Eleventh Amendment. This distinction is critical for § 1983 litigation, where municipalities can be directly liable under Monell v. Department of Social Services (1978), even though states cannot be.