The Eleventh Amendment to the United States Constitution, ratified in 1795, was a direct response to a specific legal and political context. It was designed to address issues of state sovereignty and the jurisdiction
of federal courts, following a controversial Supreme Court decision. This article delves into the historical circumstances that led to the amendment's proposal and its subsequent ratification.
The Catalyst: Chisholm v. Georgia
The Eleventh Amendment was primarily a reaction to the Supreme Court's decision in Chisholm v. Georgia in 1793. In this case, the Court ruled that states did not have sovereign immunity from suits brought by citizens of other states in federal court. This decision was based on Article III, Section 2 of the Constitution, which grants federal courts jurisdiction over cases "between a state and citizens of another state." The ruling was controversial because it challenged the notion of state sovereignty, a principle highly valued by many states.
The decision in Chisholm v. Georgia alarmed state governments, as it suggested that states could be sued in federal court without their consent. This was seen as an infringement on state sovereignty and prompted a swift response from state legislatures and Congress. The fear was that allowing such suits would lead to a flood of litigation against states, potentially bankrupting them and undermining their authority.
Proposal and Ratification Process
In response to the Chisholm decision, the Eleventh Amendment was proposed by the 3rd Congress on March 4, 1794. It was quickly passed by the House of Representatives and the Senate, reflecting the urgency with which lawmakers viewed the issue. The amendment was then sent to the states for ratification.
The ratification process was relatively swift, with the necessary number of states approving the amendment by February 7, 1795. At the time, there were fifteen states in the Union, and ratification by twelve was required to add the amendment to the Constitution. The speed of ratification indicates the widespread agreement among states on the need to protect their sovereignty from federal judicial overreach.
Impact and Legacy
The adoption of the Eleventh Amendment effectively overturned the Chisholm decision by establishing that federal courts do not have the authority to hear cases brought by private parties against a state of which they are not citizens. This restored the principle of state sovereign immunity, a cornerstone of federalism in the United States.
The amendment's impact was immediate, as seen in the 1798 Supreme Court decision in Hollingsworth v. Virginia, which resulted in the dismissal of all pending actions brought under Chisholm. The Eleventh Amendment has since been interpreted by the Supreme Court to apply broadly, reinforcing the concept of state immunity in various contexts. Its legacy continues to influence the balance of power between state and federal governments in the United States.
