Alden v. Maine

1999

Venue: SCOTUS

Facts: ME employs some people, and they think that the state violated the Fair Labor Standards Act (FLSA) provisions about overtime pay.

Posture: Filed in federal court, but the Seminole Tribe of Florida v. Florida is decided, and that says that Congress can't abrogate State sovereign immunity, so they re-file in state court. Dismissed.

Issue: Can congress require nonconsenting states to answer private suits in state court?

Holding: No. Affirmed.

Rule: 11A codifies sovereign immunity.

Reasoning: The power to press a state's own courts into federal service to coerce other branches of the state is the power to commandeer the whole machinery of the state. There are limits on that immunity: states can waive it, 14A allows some causes of action. But basically if congress wants to make states do something, they can't use the states to get it done.

Dicta: The allocation of scarce resources among competing needs an interests lies at the heart of the political process.