411 U.S. 2794 (1973).
A 1973 United States Supreme Court opinion involving issues pertaining to sovereign immunity of the Eleventh Amendment.
The case involved a lawsuit in federal court by employees of Missouri state health facilities seeking overtime pay afforded to state employees under section 216(b) of the Fair Labor Standards Act (FLSA).
The district court granted Defendants’ motion to dismiss based on the constitutional immunity of the Eleventh Amendment and the Eighth Circuit Court of Appeals affirmed.
In affirming the rulings of the lower courts, the Supreme Court held that Missouri had not constructively waived its Eleventh Amendment immunity as Plaintiffs had argued. While the Court agreed that a state participating in a federal program may constructively waive its constitutional immunity to suit in federal court when Congress intends to subject the states to federal jurisdiction by legislating pursuant to its commerce clause authority, the Court qualified that principle by holding that a state will not be found to have constructively waived its Eleventh Amendment immunity in the absence of clear congressional intent to subject the states to suit in federal court.
The Court held that there was no clear congressional intent expressed in FLSA to subject states to suit in federal court. The Court focused on the legislative history and the language of the FLSA. The Court explained that, although the term “any employer” provided in the statute could include states and their agencies, there was no evidence that Congress intended to subject the states to suit in federal court.