Wednesday, November 13, 2013

Alden v. Maine case brief

Alden v. Maine case brief summary
527 U.S. 706 (1999)

Petitioner probation officers sought review of a decision of the Maine Supreme Judicial Court, which, on the basis of sovereign immunity, affirmed a lower court's dismissal of petitioners' action against respondent employer, the State of Maine, under the Fair Labor Standards Act of 1938, 29 U.S.C.S. § 201 et seq.

Petitioner probation officers filed suit against their employer, respondent, the State of Maine, in federal court. Petitioners alleged that respondent violated the overtime provisions of the Fair Labor Standards Act of 1938 (FLSA), 29 U.S.C.S. § 201 et seq., and they sought compensation and liquidated damages. The district court dismissed petitioners' action, and the court of appeals and the state supreme court affirmed. The Court affirmed the dismissal. The Court reasoned that the powers delegated to Congress under U.S. Constitutional Article I did not include the power to subject nonconsenting states to private suits for damages in state courts and that respondent did not consent to suits for overtime pay and liquidated damages under the FLSA.

The judgment that dismissed petitioner probation officers' Fair Labor Standards Act suit on the basis of sovereign immunity was affirmed because neither the Supremacy Clause nor the enumerated powers of Congress conferred authority to abrogate respondent State's immunity from suit in federal court and respondent did not waive its immunity.

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