The Oyez Project: Federalism Issues - Natural Resources Arguments

Alden v. Maine - Oral Argument

Wed, 31 Mar 1999 12:00:00 -0500

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.

Arizona Department of Revenue v. Blaze Constr. Co. - Oral Argument

Tue, 08 Dec 1998 12:00:00 -0500

Over several years, the Federal Bureau of Indian Affairs contracted with Blaze Construction Company to build, repair, and improve roads on several Indian reservations located in Arizona. When the various contracts expired, the Arizona Department of Revenue issued a tax deficiency assessment against Blaze for its failure to pay Arizona's transaction privilege tax, the tax levied on the gross receipts of companies doing business in the state, on the proceeds from its contracts with the Bureau. Blaze protested the assessment and prevailed in administrative proceedings. On review, the Arizona Tax Court granted summary judgment for the Department. In reversing, the Arizona Court of Appeals held that federal law pre-empted the tax's application to Blaze. The Supreme Court of Arizona denied review.

Atascadero State Hospital v. Scanlon - Oral Argument

Mon, 25 Mar 1985 12:00:00 -0500

No details yet.

Bennett v. Arkansas - Oral Argument

Wed, 02 Mar 1988 12:00:00 -0500

No details yet.

Bibb v. Navajo Freight Lines Inc. - Oral Argument

Mon, 30 Mar 1959 12:00:00 -0500

The Illinois legislature adopted a law requiring all trucks and trailers traveling on the state's highways to operate with contour mudguards. The legislators believed that this specific type of mudguard would protect motorists by preventing trucks from throwing debris into the windshields of passing or trailing vehicles.

Board of Trustees v. Garrett - Oral Argument

Wed, 11 Oct 2000 12:00:00 -0500

After Patricia Garrett, Director of Nursing for the University of Alabama, was diagnosed with breast cancer, her treatment forced her to take a substantial leave from work. Upon her return, her supervisor informed her she would have to give up her position. Milton Ash, a security officer for the Alabama Department of Youth Services, who suffers from chronic asthma, requested that his employer modify his duties to accommodate him. Ultimately, none of Ash's requested relief was granted and his job performance evaluations fell. Both Garrett and Ash filed discrimination suits against their Alabama state employers, seeking money damages under Title I of the Americans with Disabilities Act of 1990 (ADA), which prohibits the States and other employers from "discriminating against a qualified individual with a disability because of that disability... in regard to... terms, conditions, and privileges of employment." The District Court disposed of both cases by ruling that the ADA exceeds Congress' authority to abrogate the State's Eleventh Amendment immunity. The Court of Appeals reversed.

Bonito Boats, Inc. v. Thunder Craft Boats, Inc. - Oral Argument

Mon, 05 Dec 1988 12:00:00 -0500

No details yet.

Central VA Comm. College v. Katz - Oral Argument

Mon, 31 Oct 2005 12:00:00 -0500

Katz, the supervisor of a bookstore that declared bankruptcy, filed a suit to collect debts owed to the bookstore by Central Virginia Community College and several other schools operated by the state of Virginia. Katz also petitioned to prevent the schools from filing claims to collect money from the bookstore because of its bankruptcy status. The colleges argued that they could not be sued by Katz because of state sovereign immunity (which holds that a state must consent in order to be sued). The bankruptcy court disagreed, however, finding that Congress's authority under the Bankruptcy Clause of the Constitution (Article I Section 8) was sufficient to allow them to waive states' sovereign immunity in bankruptcy cases.

College Savings Bank v. Florida Prepaid - Oral Argument

Tue, 20 Apr 1999 12:00:00 -0500

This case is the second tier of a patent infringement action. College Savings Bank, a New Jersey chartered bank, markets and sells certificates of deposit designed to finance college costs. Florida Prepaid Postsecondary Education Expense Board (Florida Prepaid), a Florida state entity, administers a tuition prepayment program. In addition to its original patent infringement action, College Savings filed an action alleging that Florida Prepaid violated section 43 of the Lanham Act by making misstatements about its tuition savings plans in its brochures and annual reports. The Trademark Remedy Clarification Act (TRCA) subjects states to suits brought under section 43(a) of the Lanham Act for false and misleading advertising. The District Court granted Florida Prepaid's motion to dismiss on sovereign immunity grounds. The court rejected arguments from College Savings and the United States that Florida Prepaid had waived its sovereign immunity by engaging in interstate marketing and administration of its program after the TRCA made clear that such activity would subject it to suit; and that Congress's abrogation of sovereign immunity in the TRCA was effective, since it was enacted to enforce the Fourteenth Amendment's Due Process Clause. The Court of Appeals affirmed.

Davis v. Michigan Dept. Of Treasury - Oral Argument

Mon, 09 Jan 1989 12:00:00 -0500

No details yet.

Epa v. State Water Resources Control Board - Oral Argument

Tue, 13 Jan 1976 12:00:00 -0500

No details yet.

Federal Maritime Commission v. South Carolina Ports Authority - Oral Argument

Mon, 25 Feb 2002 12:00:00 -0500

South Carolina Maritime Services, Inc. (Maritime Services), asked the South Carolina State Ports Authority (SCSPA) five times for permission to berth a cruise ship, the M/V Tropic Sea, at the SCSPA's port facilities in Charleston, South Carolina. Some cruises offered by Maritime Services would allow passengers to participate in gambling activities while on board. The SCSPA repeatedly denied Maritime Services' requests, contending that it had an established policy of denying berths in the Port of Charleston to vessels whose primary purpose was gambling. Maritime Services file a complaint with the Federal Maritime Commission (FMC), arguing that SCSPA violated the Shipping Act by its denials. The complaint was referred to an Administrative Law Judge (ALJ), who found that the SCSPA, as an arm of the State of South Carolina, was entitled to sovereign immunity and thus dismissed the complaint. Reversing on its own motion, the FMC concluded that state sovereign immunity covers proceedings before judicial tribunals, not Executive Branch agencies. In reversing, Court of Appeals fund that the proceedings were an adjudication and thus subject to state sovereign immunity.

Florida Prepaid v. College Savings Bank - Oral Argument

Tue, 20 Apr 1999 12:00:00 -0500

Immediately after the Patent and Plant Variety Protection Remedy Clarification Act (Act) changed patent laws to abrogate state's sovereign immunity, College Savings Bank (College) filed a patent infringement suit against Florida Prepaid Postsecondary Education Expense Board (Florida Prepaid), a Florida state entity. Florida Prepaid asked that College's suit be dismissed and that the Act be declared unconstitutional, based on Seminole Tribe of Florida v. Florida (517 US 44) which upheld state sovereign immunity. The United States joined College looking to uphold the Act's constitutionality. After agreeing with College, the District Court denied Florida Prepaid's dismissal motion. When the Federal Circuit affirmed, Florida Prepaid appealed and the Supreme Court granted certiorari.

Frew v. Hawkins - Oral Argument

Tue, 07 Oct 2003 12:00:00 -0500

In 1996, Linda Frew and other citizens settled a class-action lawsuit in federal district court against the Texas Health and Human Services Commission. Settlement was reached through a consent agree, in which the parties make an agreement that is subject to court supervision. As part of this consent decree, Texas was supposed to improve health care for poor children to comply with a federally mandated program called Early and Periodic Screening, Diagnosis and Treatment. Two years later, Frew and others remained unsatisfied that Texas was complying with the federal requirements, and asked the court to force Texas to create a plan for how it would improve health care. Texas refused, however, claiming that it was immune from the court order under the 11th Amendment, which provides for state sovereignty. Texas argued that because no federal rights had been violated, suit could not be brought in federal court. The Fifth Circuit Court of Appeals agreed with Texas.

Garcia v. San Antonio Metro. Transit Authority - Oral Argument

Mon, 19 Mar 1984 12:00:00 -0500

The San Antonio Metropolitan Transit Authority (SAMTA), the main provider of transportation in the San Antonio metropolitan area, claimed it was exempt from the minimum-wage and overtime requirements of the Fair Labor Standards Act. SAMTA argued that it was providing a "traditional" governmental function, which exempted it from federal controls according to the doctrine of federalism established in National League of Cities v. Usery (1976). Joe G. Garcia, an employee of SAMTA, brought suit for overtime pay under Fair Labor Standards Act.

Garcia v. San Antonio Metro. Transit Authority - Oral Reargument

Mon, 01 Oct 1984 12:00:00 -0500

Hancock v. Train - Oral Argument

Tue, 13 Jan 1976 12:00:00 -0500

No details yet.

Hibbs v. Winn - Oral Argument

Tue, 20 Jan 2004 12:00:00 -0500

Several Arizona residents challenged in federal district court an Arizona statute that allows tax credits for money spent toward parochial schools. They alleged that the statute violates the religious establishment clause of the U.S. Constitution's First Amendment.

The district court dismissed the case and ruled that it lacked jurisdiction for two reasons: First, the federal Tax Injunction Act (TIA) prohibits federal district courts from ruling on the "assessment, levy or collection of any tax under state law where a plain, speedy and efficient remedy may be had in the courts of such state." And second, the court pointed to the comity doctrine - that is, the deference that federal courts should generally give to state tax laws. The Ninth Circuit Court of Appeals reversed, ruling that neither the TIA nor comity place the case outside federal jurisdiction. The court reasoned that the TIA was inapplicable because invalidating a tax credit would not harm Arizona's ability to raise revenue.

Howlett v. Rose - Oral Argument

Tue, 20 Mar 1990 12:00:00 -0500

No details yet.

Idaho v. Coeur D'Alene Tribe of Idaho - Oral Argument

Wed, 16 Oct 1996 12:00:00 -0500

The Coeur d'Alene Tribe (the Tribe) of Idaho filed an action against the State of Idaho, various state agencies, and numerous state officials alleging ownership of the submerged lands and bed of Lake Coeur d'Alene and various navigable tributaries and effluents lying within the original boundaries of the Coeur d'Alene Reservation. The Tribe sought a declaratory judgment establishing its entitlement to the exclusive use and occupancy and the right to quiet enjoyment of the submerged lands, a declaration of the invalidity of all Idaho laws, customs, or usages purporting to regulate those lands, and a preliminary and permanent injunction prohibiting defendants from taking any action in violation of the Tribe's rights in the lands. Ultimately, the District Court dismissed all the components of the complaint on Eleventh Amendment immunity grounds, for failure to state a claim upon which relief could be granted, and on the merits. The Court of Appeals affirmed that the Eleventh Amendment barred all claims against the State and its agencies, as well as the title action against the officials. However, it allowed the claims for declaratory and injunctive relief against the state officials to proceed insofar as they sought to preclude continuing violations of federal law. The court reasoned that those claims were based on Idaho's ongoing interference with the Tribe's alleged ownership rights, and found it conceivable that the Tribe could prove facts entitling it to relief on the claims.

James M. Beam Distilling Co. v. Georgia - Oral Argument

Tue, 30 Oct 1990 12:00:00 -0500

No details yet.

Lapides v. Board of Regents of University System of Georgia - Oral Argument

Mon, 25 Feb 2002 12:00:00 -0500

Paul Lapides, a professor employed by the Georgia state university system, filed a state-court lawsuit against the system?s board of regents and other university officials, alleging that the officials had violated state tort law and 42 USC section 1983 when they placed sexual harassment allegations in his personnel files. The defendants removed the case to Federal District Court and then sought a dismissal. Conceding that a state statute had waived Georgia's sovereign immunity from state-law suits in state court, the State claimed Eleventh Amendment immunity from suit in the federal court. The District Court held that Georgia had waived such immunity when it removed the case to federal court. In reversing, the Court of Appeals found that, because state law was unclear as to whether the state attorney general had the legal authority to waive Georgia's Eleventh Amendment immunity, the State retained the legal right to assert immunity, even after the removal.

Lawrence County v. Lead-Deadwood School Dist. - Oral Argument

Tue, 30 Oct 1984 12:00:00 -0500

No details yet.

National League of Cities v. Usery - Oral Reargument

Tue, 02 Mar 1976 12:00:00 -0500

In 1974, Congress passed amendments to the Fair Labor Standards Act of 1938. The purpose of the amendments was to regulate minimum wage and overtime pay for state and local government employees. The National League of Cities, as well as several states and cities, challenged the constitutionality of the amendments.

Nevada Dept. of Human Resources v. Hibbs - Oral Argument

Wed, 15 Jan 2003 12:00:00 -0500

William Hibbs, an employee of the Nevada Department of Human Resources, sought leave to care for his wife under the Family and Medical Leave Act of 1993 (FMLA). The FMLA entitles an eligible employee to take up to 12 workweeks of unpaid leave annually for the onset of a "serious health condition" in the employee's spouse. The Department granted Hibbs's request for the full 12 weeks of FMLA leave and, after he had exhausted that leave, informed him that he must report to work by a certain date. When Hibbs failed to do so, he was fired. Pursuant to FMLA provisions creating a private right of action "against any employer" that "interfered with, restrained, or denied the exercise of" FMLA rights, Hibbs sued in Federal District Court, seeking money damages for FMLA violations. The District Court concluded that the Eleventh Amendment barred the FMLA claim. The Court of Appeals reversed.

New York v. United States - Oral Argument

Mon, 30 Mar 1992 12:00:00 -0500

The Low-Level Radioactive Waste Management Act Amendments of 1985 required states alone or in compacts with other states to dispose of such radioactive waste within their borders. New York State and Allegany and Courtland counties were frustrated in their compliance efforts by resistance from residents to proposed radioactive waste sites and a lack of cooperation from neighboring states. New York filed suit against the federal government, questioning the authority of Congress to regulate state waste management.

Pennhurst State School & Hosp. v. Halderman - Oral Argument

Tue, 22 Feb 1983 12:00:00 -0500

No details yet.

Pennhurst State School & Hosp. v. Halderman - Oral Reargument

Mon, 03 Oct 1983 12:00:00 -0500

No details yet.

Pennsylvania v. Union Gas Co. - Oral Argument

Mon, 31 Oct 1988 12:00:00 -0500

No details yet.

Printz v. United States - Oral Argument

Tue, 03 Dec 1996 12:00:00 -0500

The Brady Handgun Violence Prevention Act (Brady Bill) required "local chief law enforcement officers" (CLEOs) to perform background-checks on prospective handgun purchasers, until such time as the Attorney General establishes a federal system for this purpose. County sheriffs Jay Printz and Richard Mack, separately challenged the constitutionality of this interim provision of the Brady Bill on behalf of CLEOs in Montana and Arizona respectively. In both cases District Courts found the background-checks unconstitutional, but ruled that since this requirement was severable from the rest of the Brady Bill a voluntary background-check system could remain. On appeal from the Ninth Circuit's ruling that the interim background-check provisions were constitutional, the Supreme Court granted certiorari and consolidated the two cases deciding this one along with Mack v. United States.

Ray v. Atlantic Richfield Co. - Oral Argument

Mon, 31 Oct 1977 12:00:00 -0500

No details yet.

Reno v. Condon - Oral Argument

Wed, 10 Nov 1999 12:00:00 -0500

State departments of motor vehicles (DMVs) require drivers and automobile owners to provide personal information, which may include a person's name, address, telephone number, Social Security number, and photograph, as a condition of obtaining a driver's license or registering an automobile. Congress enacted the Driver's Privacy Protection Act of 1994 (DPPA),which establishes a regulatory scheme that restricts the States' ability to disclose a driver's personal information without the driver's consent, after finding that many States sell such information. The DPPA conflicts with South Carolina law, under which information contained in the State's DMV records is available to any person or entity that fills out a form listing the requester's name and address and stating that the information will not be used for telephone solicitation. The Attorney General of South Carolina filed suit, alleging the DPPA violated the Tenth and Eleventh Amendments. The District Court concluded that the DPPA was incompatible with the principles of federalism, granted summary judgement for the State, and permanently enjoined the DPPA's enforcement against the State. In affirming, the Court of Appeals also concluded that the DPPA violated the constitutional principles of federalism.

Sabri v. United States - Oral Argument

Wed, 03 Mar 2004 12:00:00 -0500

Basim Omar Sabri, a Minneapolis landlord and developer, tried to bribe a Minneapolis City Council member who sat on the board of an organization that dispersed funding for economic revitalization of city neighborhoods. Some of the funds dispersed by the organization were federal funds.

Sabri was charged in federal court with bribery. He moved to dismiss the charges, claiming that the section of United States Code that he was charged under was unconstitutional. He claimed that Congress could only regulate the dispersal of federal funds; because the statute did not require the prosecutors to show that the bribery had affected any federal funds, only that it had affected an organization that received federal funds, he argued that it was outside of Congress's power to legislate. The district court sided with Sabri and dismissed the charges.

On appeal, an Eighth Circuit Court of Appeals panel reversed. It found that, because federal funds were often mixed with other funds by organizations that distributed them, it would be difficult for prosecutors to prove that the funds affected by an attempted bribe were federal funds. As a result, the government would have to regulate all bribes to organizations that dispersed federal funds in order to meaningfully protect federal funds. Because Congress had authority under the necessary and proper clause and the spending clause (both found in Article I, Section 8 of the Constitution) to ensure that government funds were not misspent, the bribery statute was therefore constitutional.

Seminole Tribe v. Florida - Oral Argument

Wed, 11 Oct 1995 12:00:00 -0500

The Seminole Tribe brought suit against the State of Florida for violating the good faith negotiations requirement of the Indian Gaming Regulatory Act (IGRA). Under the IGRA, the Tribe may engage in gaming (i.e., casino gambling) activities subject to Florida's good faith regulations. Florida moved to dismiss the Tribe's action, alleging that the lawsuit violated Florida's sovereign immunity. On appeal from the District Court's denial of Florida's motion to dismiss the lawsuit, the Court of Appeals reversed, holding that the Eleventh Amendment shielded Florida from federal suit and that under Ex Parte Young, the Tribe may not enforce its right to good faith negotiations by naming Florida's governor as a party to the suit.

South Dakota v. Dole - Oral Argument

Tue, 28 Apr 1987 12:00:00 -0500

In 1984, Congress enacted legislation ordering the Secretary of Transportation to withhold five percent of federal highway funds from states that did not adopt a 21-year-old minimum drinking age. South Dakota, a state that permitted persons 19 years of age to purchase alcohol, challenged the law.

South-Central Timber Dev. v. Wunnicke - Oral Argument

Wed, 29 Feb 1984 12:00:00 -0500

No details yet.

Tennessee Student Assistance Corporation v. Hood - Oral Argument

Mon, 01 Mar 2004 12:00:00 -0500

Pamela Hood had an outstanding debt to the Tennessee Student Assistance Corporation, a loan-granting institution established by the state, when she filed for bankruptcy. The state objected to her request that the debt be forgiven ("discharged" in the terms of bankruptcy law) by the federal bankruptcy court, arguing that to discharge the debt would violate the state's sovereign immunity (that is, its right not to be sued). Hood countered that the Federal Rules of Bankruptcy Procedure allow student loan debts to be discharged if the bankruptcy filer can demonstrate that they will suffer "undue hardship" if the debt is not forgiven, and that this congressional permission is a constitutional waiver of state sovereign immunity because it falls under the power granted to Congress by the Bankruptcy Clause (Article I, Section 8 of the U.S. Constitution).

The bankruptcy court sided with Hood, finding that Congress had acted constitutionally in waiving the states' sovereign immunity. The Sixth Circuit Bankruptcy Appellate Panel affirmed, as did a normal panel of the Sixth Circuit.

United States v. County Of Fresno - Oral Argument, Part 1

Mon, 08 Nov 1976 12:00:00 -0500

No details yet.

United States v. County Of Fresno - Oral Argument, Part 2

Mon, 08 Nov 1976 12:00:00 -0500

No details yet.

United States v. Georgia - Oral Argument

Wed, 09 Nov 2005 12:00:00 -0500

Goodman, a paraplegic held in a Georgia state prison, sued Georgia in federal court for maintaining prison conditions that allegedly discriminated against disabled people and violated Title II of the Americans with Disabilities Act (ADA). Georgia claimed the 11th Amendment provided the state immunity from such suits. The district court ruled for Georgia, but the 11th Circuit reversed.

Before the 11th Circuit ruled in the case, the United States sued Georgia, arguing that the ADA's Title II abolished state sovereign immunity from monetary suits. Congress could do this, the U.S. argued, by exercising its 14th Amendment power to enforce equal protection.

Verizon Maryland Inc. v. Public Service Commission of Maryland - Oral Argument

Wed, 05 Dec 2001 12:00:00 -0500

The Telecommunications Act of 1996 requires that incumbent local-exchange carriers (LECs) provide interconnection with their existing networks; that the carriers then establish reciprocal compensation arrangements for transporting and terminating the calls of each others' customers; and that their interconnection agreements be approved by a state utility commission. Verizon Maryland Inc., the incumbent LEC in Maryland, negotiated an interconnection agreement with MCI WorldCom, Inc. After the Maryland Public Service Commission approved the agreement, Verizon informed WorldCom that it would no longer pay reciprocal compensation for calls made by Verizon's customers to the local access numbers of Internet Service Providers (ISPs) because ISP traffic was not local traffic subject to the reciprocal compensation agreement. WorldCom filed a complaint with the Commission, which ordered Verizon to make the payments for past and future ISP-bound calls. Verizon then filed an action in federal district court, seeking an injunction prohibiting its enforcement, alleging that the determination that Verizon must pay reciprocal compensation for ISP traffic violated the Act. The District Court dismissed the action. In affirming, the Court of Appeals held that the Commission had not waived its Eleventh Amendment immunity and that the Act did not provide a basis for jurisdiction over Verizon's claims.