Idaho v. Coeur D’alene Tribe of Idaho

Summary

The Court held that Idaho's Eleventh Amendment immunity bars the Tribe's claims against state officials because the requested declaratory and injunctive relief would function as a quiet title decree and eliminate the State's regulatory authority over submerged lands implicating special sovereignty interests. It reversed the Court of Appeals in part and remanded without deciding ownership. Justice Kennedy wrote for five Justices in Parts I, II–A, and III; only Chief Justice Rehnquist joined his additional discussion advocating a contextual balancing approach to Ex parte Young. Justice O'Connor, joined by Justices Scalia and Thomas, concurred in part and in the judgment, accepting the narrow submerged-lands rationale but rejecting a general balancing test or reliance on the availability of state courts. Justice Souter, joined by Justices Stevens, Ginsburg, and Breyer, dissented, reasoning that the Tribe alleged an ongoing violation of federal law and sought prospective relief within the established Young doctrine.