Seminole Tribe of Florida v. Florida
Citation and Court
517 U.S. 44 (1996) — Supreme Court of the United States
Facts
The Indian Gaming Regulatory Act (IGRA) required states to negotiate in good faith with Indian tribes toward a gaming compact and authorized tribes to sue in federal court if a state refused. The Seminole Tribe sued Florida in federal court after Florida refused to negotiate. Florida raised an Eleventh Amendment defense.
Issue
Whether Congress may abrogate state Eleventh Amendment sovereign immunity through legislation enacted pursuant to its Article I powers, specifically the Indian Commerce Clause.
Holding
No. Congress may not use its Article I powers to abrogate state sovereign immunity under the Eleventh Amendment; only Congress’s enforcement power under § 5 of the Fourteenth Amendment provides a valid basis for abrogating state immunity.
Rule / Doctrine
Article I cannot be used to abrogate state sovereign immunity. The Eleventh Amendment reflects a fundamental aspect of state sovereignty that antedates the Constitution, and Congress may override it only through later-enacted constitutional provisions that subordinate state sovereignty — specifically, § 5 of the Fourteenth Amendment. Pennsylvania v. Union Gas (1989) is overruled.
Significance
Seminole Tribe is one of the most consequential federalism decisions of the Rehnquist Court era, dramatically limiting Congress’s ability to expose states to suit in federal court. Combined with City of Boerne v. Flores, it creates a two-step barrier: Congress must act under § 5 of the Fourteenth Amendment (not Article I), and the legislation must satisfy the congruence-and-proportionality test.