Chisholm v. Georgia
Chisholm v. Georgia was a landmark Supreme Court case decided in 1793 that addressed the balance between state sovereignty and federal authority. The case arose when two citizens from South Carolina sought to recover property that the state of Georgia had confiscated during the American Revolution. Georgia refused to participate in the lawsuit, claiming sovereign immunity, which traditionally protected states from being sued without their consent. However, the Supreme Court ruled 4-1 in favor of the plaintiffs, asserting that the federal judiciary had the authority to hear cases involving states and citizens of other states.
This decision was rooted in a nationalistic interpretation of the Constitution, where justices argued that the Constitution was established by the people as sovereigns, allowing citizens to sue states. The dissenting opinion highlighted concerns about the implications for states’ rights and sovereignty. The backlash against the ruling was significant among proponents of states’ rights, leading to the ratification of the Eleventh Amendment, which restricted the ability of individuals to sue states in federal court. Chisholm v. Georgia remains a significant moment in the evolution of federalism in the United States.
Chisholm v. Georgia
Date: February 18, 1793
Citation: 2 Dall. (2 U.S.) 419
Issue: State sovereignty
Significance: In its first major decision, the Supreme Court held that the U.S. Constitution allowed a citizen of one state to sue another state in federal court.
Article III of the U.S. Constitution granted federal jurisdiction over “controversies between a state and citizens of another state.” During ratification of the Constitution, Federalists asserted that this provision would not override the doctrine of sovereign immunity, which meant that the government may be sued only with its consent. Two South Carolina citizens, executors of an estate of a British decedent, attempted to recover property that Georgia had confiscated during the American Revolution. Georgia refused to appear, claiming immunity as a sovereign state.
By a 4-1 vote, the Supreme Court ruled against the state and endorsed the authority of the federal judiciary over the states. In seriatim opinions, Justices John Jay and James Wilson emphasized strong nationalistic views. They declared that the people of the United States had acted “as sovereigns” in establishing the Constitution and that the states, by virtue of membership in a “national compact,” could be sued by citizens throughout the nation. In dissent, Justice James Iredell, a southerner who had participated in a ratifying convention, argued that the English common law doctrine of sovereign immunity had not been superseded by constitutional provision or by statute.
The Chisholm decision was bitterly denounced by partisans of states’ rights. The controversy resulted in the drafting and ratification of the Eleventh Amendment, the first of four amendments to directly overrule a decision of the Court.