ALDEN V. MAINE
527 U.S. 706 (1999)
NATURE OF THE CASE: This was a dispute over overtime pay under the FLSA relating to
Congressional power to enforce the Act against States.
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.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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