Historical Context and Ratification
Chisholm v. Georgia was highly controversial. When a South Carolina man tried to make Georgia pay its debts, Georgia reacted strongly. The Court's 1793 decision to allow this suit led directly to the Eleventh Amendment.
Anti-Federalists had worried about such scenarios, fearing states would face federal suits without consent. The Chisholm ruling seemed to prove them right. Federalists, who had said states wouldn't be sued under Article III, were in a tight spot.
Senator Caleb Strong proposed what became the Eleventh Amendment. Ratified in 1795, it stated:
"The Judicial power of the United States shall not be construed to extend to any suit in law or equity, commenced or prosecuted against one of the United States by Citizens of another State, or by Citizens or Subjects of any Foreign State."
This directly countered the Chisholm verdict.
Subsequent landmark cases further shaped the interpretation of state immunity:
- Hans v. Louisiana (1890): Solidified state immunity, barring federal suits by citizens against their own states.
- Ex Parte Young (1908): Allowed suits against state officials for unconstitutional acts, creating a narrow exception.
- Federal Maritime Commission v. South Carolina State Ports Authority: Extended immunity to federal agency proceedings.
The Eleventh Amendment was a reaction to perceived federal overreach, reshaping federal court jurisdiction and authority.

Interpretation and Expansion
The Supreme Court has expanded the Eleventh Amendment's meaning far beyond its text. Key decisions include:
- Hans v. Louisiana (1890): Barred suits against states by their own citizens in federal court.
- Ex Parte Young (1908): Allowed suits against state officials for injunctive relief when violating federal law.
- Seminole Tribe of Florida v. Florida (1996): Ruled Congress couldn't authorize lawsuits against unconsenting states under the Commerce Clause.
- Alden v. Maine (1999): Extended state immunity to suits in their own courts for violating federal laws.
- Federal Maritime Commission v. South Carolina State Ports Authority (2002): Applied state immunity to federal agency proceedings.
These decisions have significantly expanded state sovereignty, reshaping federalism in ways the framers might not have anticipated. The only exception remains legislation under the Fourteenth Amendment.
This judicial interpretation has created a complex landscape of state immunity, balancing federal power and state sovereignty in ways that continue to evolve.

Sovereign Immunity Doctrine
Sovereign immunity, rooted in common law, shields states from lawsuits. The Eleventh Amendment cemented this principle in U.S. law. Hans v. Louisiana expanded this protection, preventing citizens from suing their own states in federal court.
Key exceptions and nuances to sovereign immunity include:
- Ex Parte Young: Allows suits against state officials acting unconstitutionally.
- Fourteenth Amendment: Provides an exception, allowing Congress to subject states to suits (Fitzpatrick v. Bitzer).
- Clear language requirement: Congress must use explicit language to override state immunity.
- Involuntary bankruptcy cases: An exception as ruled in Central Virginia Community College v. Katz.
- State subdivisions: Cities and counties don't enjoy the same immunity as states.
- Voluntary waiver: States can waive immunity by participating in federal court proceedings (Barnard v. Clark).
Sovereign immunity remains a dynamic principle in American federalism, constantly balancing state sovereignty with federal power. Its interpretation continues to evolve through judicial decisions, shaping the complex relationship between state and federal authority.

Congressional Power and Limitations
Congress's ability to override state sovereign immunity isn't unrestricted. The Fourteenth Amendment is crucial, serving as a legislative tool Congress can use to pierce state immunity.
Fitzpatrick v. Bitzer (1976) established that Congress could authorize federal courts to hear suits against states for violations of Fourteenth Amendment rights. This provided a path to pierce state immunity on Fourteenth Amendment grounds.
Article I powers, however, are more limited. In Seminole Tribe v. Florida (1996), the Court ruled that Congress lacks power under Article I to authorize lawsuits against unconsenting states. This decision nullified an earlier, broader interpretation in Pennsylvania v. Union Gas Co.
Alden v. Maine (1999) further reinforced this point, ruling that states couldn't be sued in their own courts for federal law violations under Congress's Article I powers.
The Court has also employed a strict "clear statement rule" for Fourteenth Amendment-based abrogation of state immunity. Congress must make its intent to override state immunity explicitly clear, as seen in Atascadero State Hospital v. Scanlon (1985).
Despite the Fourteenth Amendment's exception, the overall framework remains firmly in favor of state immunity. States retain their sovereign status, protected against lawsuits unless explicitly overridden by a Fourteenth Amendment-empowered Congress.

Modern Applications and Controversies
The Eleventh Amendment continues to impact modern legal cases. Recent examples include:
- Mick v. Gibbons: The Nebraska State Patrol (NSP) cited sovereign immunity to resist a subpoena in a case involving a death during a law enforcement encounter.
- NetChoice v. Paxton and Moody v. NetChoice: These cases involve challenges to state laws regulating social media content moderation.
In the NetChoice cases, the Supreme Court provided guidelines on how First Amendment principles apply to social media. The Court ruled that:
Laws infringing on platforms' editorial discretion violate the First Amendment, equating social media editorial functions to those of traditional press editors.
However, the ruling left open questions about:
- How this First Amendment protection applies to other online functions
- The role of AI-driven content moderation in these protections
These cases demonstrate the Eleventh Amendment's ongoing role in shaping state and federal relations, balancing state sovereignty with federal oversight in both traditional and emerging legal contexts.

The Eleventh Amendment remains a critical component in maintaining state sovereignty within the American federal system, continually shaping the balance of power between state and federal authorities.