Hoffman v. Connecticut Department of Income Maintenance

Summary

The Court held that § 106(c) of the Bankruptcy Code does not unmistakably abrogate the States’ Eleventh Amendment immunity from monetary recovery. Because the States had not filed proofs of claim, the trustee’s actions to recover Medicaid payments and avoid a preferential tax payment were barred, and the Court affirmed. Justice Marshall and Justice Stevens dissented, while Justice O’Connor concurred in the judgment on the ground that Congress lacked power under the Bankruptcy Clause to abrogate state immunity.