FLORIDA DEPT. OF STATE v. TREASURE SALVORS, INC.

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Case Basics
Docket No. 
80-1348
Petitioner 
Florida Dept. of State
Respondent 
Treasure Salvors, Inc.
Advocates
(Argued the cause pro hac vice for the petitioner)
(Argued the cause for the respondent)
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Term:
Facts of the Case 

Immediately after Treasure Salvors, Inc. ("Treasure") located a 17th-century Spanish wreck of its coast, Florida claimed ownership of the remains. Treasure contracted with the Florida Division of Archives ("Archives") to salvage the wreck in exchange for 75% of the recovered artifacts' appraised value. Meanwhile, in the unrelated proceedings of United States v. Florida, the United States won a judgment granting it ownership of the lands, minerals, and other natural resources in the area of the Spanish wreck's discovery. Upon learning of this ruling, Treasure sought a declaration of title to the wreck. Following a second favorable appellate decision, Treasure sought and received a warrant to seize all artifacts from the Archives. Florida challenged the warrant and its issuing district court's jurisdiction, but lost on both counts. On appeal from an unfavorable appellate ruling, the Supreme Court granted Florida certiorari.

Question 

Does a district court's issuance of a property seizure warrant against a state violate the Eleventh Amendment?

Conclusion 
Decision: 5 votes for Treasure Salvors, Inc., 4 vote(s) against
Legal provision: Amendment 11: Eleventh Amendment

No. In a plurality opinion, the Court first held that while a state enjoys limited immunity from federal process under the Eleventh Amendment, its officers do not. In the present case, the seizure warrant was filed against Florida's officers in the Archives. The Archive officers, although acting in official state capacity and defended by state attorneys, are not immune as the state itself may be from having to pay a judgment against them. Moreover, the Court found that although a profit sharing contract existed between Treasure and Archives, it did not justify Archive's refusal to surrender ownership over the artifacts pursuant to a federal warrant. Finally, the Court ruled that the district court lacked jurisdiction to adjudicate Florida's interest in the artifacts because these materials were held in a different district court's jurisdiction. As such, the decision was reversed in part and remanded as to its jurisdictional violations.

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FLORIDA DEPT. OF STATE v. TREASURE SALVORS, INC.. The Oyez Project at IIT Chicago-Kent College of Law. 24 November 2014. <http://www.oyez.org/cases/1980-1989/1981/1981_80_1348>.
FLORIDA DEPT. OF STATE v. TREASURE SALVORS, INC., The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1980-1989/1981/1981_80_1348 (last visited November 24, 2014).
"FLORIDA DEPT. OF STATE v. TREASURE SALVORS, INC.," The Oyez Project at IIT Chicago-Kent College of Law, accessed November 24, 2014, http://www.oyez.org/cases/1980-1989/1981/1981_80_1348.