Alden v. Maine

527 U.S. 706 (1999)

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Nature of the Case

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Facts

In 1992, petitioners, a group of probation officers, filed suit against the State of Maine, in the United States District Court. The officers alleged the State had violated the overtime provisions of the Fair Labor Standards Act of 1938 (FLSA) and sought compensation and liquidated damages. While the suit was pending, the Supreme Court decided Seminole Tribe of Fla. v. Florida, which made it clear that Congress lacks power under Article I to abrogate the States' sovereign immunity from suits commenced or prosecuted in the federal courts. The District Court dismissed petitioners' action, and the Court of Appeals affirmed. Petitioners then filed the same action in state court. The state trial court dismissed the suit on the basis of sovereign immunity, and the Maine Supreme Judicial Court affirmed. The Maine Supreme Judicial Court's decision conflicts with the decision of the Supreme Court of Arkansas and calls into question the constitutionality of the provisions of the FLSA purporting to authorize private actions against States in their own courts without regard for consent. The Supreme Court granted certiorari.