Hoffman v. Connecticut Department of Income Maintenance

Summary

The Court held that the Bankruptcy Code’s § 106(c) does not unmistakably abrogate the States’ Eleventh Amendment immunity from monetary recovery in bankruptcy proceedings. Because the States had not filed proofs of claim, the trustee could not use the turnover and preference provisions to obtain money judgments against them, and the Court therefore affirmed. Justice O’Connor concurred in the judgment, while Justices Marshall, Brennan, Blackmun, and Stevens dissented on the statutory interpretation and congressional-authority issues.