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What was the Seminole Tribe of Florida v.
Florida case about?
The Seminole Tribe's lawsuit against the state of Florida was the first time a Native American tribe had sued a state under the Indian Gaming Regulatory Act (IGRA).
Prior to this case, the Supreme Court had consistently upheld Congress's power to abrogate state sovereign immunity under laws passed pursuant to the Commerce Clause, such as the Indian Commerce Clause.
The Seminole Tribe argued that the IGRA required Florida to negotiate a gaming compact with the tribe in good faith, but Florida had refused to do so.
Florida contested the lawsuit, claiming that the Eleventh Amendment protected it from being sued by the Seminole Tribe in federal court.
This decision overturned the Court's earlier ruling in Pennsylvania v.
Union Gas Co., which had upheld Congress's authority to abrogate state sovereign immunity under the Commerce Clause.
The Court's reasoning was that the Eleventh Amendment's protection of state sovereign immunity was a fundamental principle of the Constitution that could not be overridden by an act of Congress.
The decision significantly limited the ability of Native American tribes to sue states in federal court to compel them to negotiate gaming compacts under IGRA.
It also called into question Congress's power to abrogate state sovereign immunity in other areas of federal law passed pursuant to the Commerce Clause.
In response, Congress later passed the Indian Self-Determination Act, which provided an alternative avenue for tribes to sue states that failed to negotiate gaming compacts in good faith.
The Seminole Tribe case was an important precedent that shaped the balance of power between states and Native American tribes in the realm of gaming regulation.
It highlighted the ongoing tensions between tribal sovereignty and state sovereignty under the U.S.
federal system of government.
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