Significance: In this case, the Supreme Court ruled that the federal government had authority over the states in claims between a state and citizens of another state. This decision led to the Eleventh Amendment, which limited the Court's jurisdiction to rule in cases involving individual states. This decision was the first time a Supreme Court decision was overruled by a Constitutional amendment.
Background: During the Revolutionary War, a South Carolina merchant supplied clothing to the state of Georgia. However, the state refused to pay the merchant. After the merchant's death, Alexander Chisholm, who was in charge of the estate, sued the state for the value of the clothing. The state refused to appear before the Supreme Court. Georgia claimed that it was immune from such a lawsuit because it was a sovereign and independent state. This conflict reflected an ongoing debate about whether the powers of the federal government should be strong or weak.
Decision: This case was argued on February 5, 1793, and decided on February 18, 1793, by a vote of 4 to 1. Following the practice of the Court at that time, each justice gave a separate opinion. The majority decided against Georgia. Justices John Jay and James Wilson argued that authority resided in the people and not the states. Therefore, Georgia was not independent. In addition, the Constitution gave the Supreme Court the power to rule in cases that involved individual states. This ruling raised fears that the federal government, especially the judiciary, was becoming too powerful. The ruling led to the passage in 1798 of the Eleventh Amendment, which forbids a citizen from one state to sue another state in federal court without the consent of the state being sued.
Excerpt from Justice Cushing’s Opinion: “The grand and principal question in this case is, whether a State can, by the Federal Constitution, be sued by an individual citizen of another State? The point turns . . . upon the Constitution established by the people of the United States; and particularly upon the extent of powers given to the Federal Judicial in the second section of the third article of the Constitution. . . . The judicial power, then, is expressly extended to ‘controversies between a State and citizens of another State.’ When a citizen makes a demand against a State, of which he is not a citizen, it is as really a controversy between a State and a citizen of another State, as if such State made a demand against such citizen. The case, then, seems clearly to fall within the letter of the Constitution.”
