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Judicial Power & Separation of Powers

Seminole Tribe of Florida v. Florida

Decided: 1996

In brief

Congress cannot use its Article I powers to abrogate state sovereign immunity under the Eleventh Amendment.

The Court's ruling in depth

The Indian Gaming Regulatory Act let tribes sue states in federal court to compel good-faith gaming compact negotiations. Florida invoked sovereign immunity. Chief Justice Rehnquist held that the Eleventh Amendment reflects a broader constitutional principle of state sovereign immunity that Congress may abrogate only under § 5 of the Fourteenth Amendment — not under Article I's Commerce or Indian Commerce Clauses. Seminole Tribe launched the modern 'federalism revolution' (Alden v. Maine, Kimel, Garrett) and remains one of the most consequential state-sovereignty rulings in U.S. history.

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