Seminole Tribe of Florida v. Florida

Summary

The United States Supreme Court held that Congress lacked authority under the Indian Commerce Clause to abrogate the States’ sovereign immunity for suits brought under the Indian Gaming Regulatory Act. The Court also held that the Ex parte Young doctrine did not permit the Tribe to enforce the Act’s good-faith negotiation requirement against Florida’s Governor. The Court affirmed the Eleventh Circuit’s dismissal of the Seminole Tribe’s suit.

Holdings

1. Although Congress unmistakably intended the Indian Gaming Regulatory Act to abrogate the States' sovereign immunity, the Indian Commerce Clause does not grant Congress authority to abrogate that immunity. Accordingly, 25 U.S.C. § 2710(d)(7) cannot confer federal jurisdiction over an unconsenting State.
2. Ex parte Young does not permit the Tribe to sue the Governor of Florida to compel compliance with the Indian Gaming Regulatory Act's good-faith negotiation requirement where Congress enacted a detailed remedial scheme specifically governing enforcement of that right.

Questions Presented

1. Whether Congress may abrogate a State's Eleventh Amendment sovereign immunity pursuant to its power under the Indian Commerce Clause.
2. Whether the Ex parte Young doctrine permits an Indian tribe to sue a State's Governor for prospective injunctive relief enforcing the Indian Gaming Regulatory Act's good-faith negotiation requirement.

Disposition

affirmed