Alden v. Maine Case Brief

Why is the case important?

The Petitioners, a group of probation officers (Petitioners), brought suit in Maine State Court, alleging that their employer, the State of Maine (Respondent) violated overtime provisions of the federal Fair Labor Standards Act (“FLSA”).

Facts of the case

A group of probation officers sued their employer, the State of Maine, in 1992 alleging that the state had violated the overtime provisions of the 1938 Fair Labor Standards Act. Following the Court’s decision in Seminole Tribe v. Florida (1996) which held that States are immune from private suits in federal court and that Congress lacks the authority to abrogate that immunity the probation officers’ suit was dismissed in Federal district court. Alden and the other probation officers then sued Maine again for violating the Fair Labor Standards Act, this time in state court. The state trial court and the state supreme court both held that Maine had sovereign immunity and could not be sued by private parties in their own court.

Question

May Congress require non-consenting states to submit to private suits in their own courts under Article I?

Answer

No. State Supreme Court ruling affirmed.
The United States Supreme Court (Supreme Court) recounts the judicial development of the doctrine of state sovereign immunity and its application in the federal courts.
The Supreme Court rules that to allow Congress to bring a non-consenting state into state court when it could not do so in federal court would make hollow the doctrine of sovereign immunity.

Conclusion

“The Court held that the district court rendered the correct decision

  • hence, it affirmed the dismissal of the petitioners’ action. The Court reasoned that the powers delegated to Congress under U.S. Const. Art. I did not include the power to subject nonconsenting states to private suits for damages in state courts and that respondent did not consent to suits for overtime pay and liquidated damages under the FLSA.”
    • Case Brief: 1999
    • Petitioner: Alden
    • Respondent: Maine
    • Decided by: Rehnquist Court

    Citation: 527 US 706 (1999)
    Argued: Mar 31, 1999
    Decided: Jun 23, 1999