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Which Supreme Court case first recognized a state sovereign immunity limitation on Congress’s enforcement powers under Section 5 of the 14th Amendment?

WRONG! Chisholm v. Georgia (1793) actually led to the 11th Amendment, which explicitly granted state sovereign immunity from suits by citizens of another state—but didn’t involve Section 5 powers or modern federalism limits.

CORRECT! In Seminole Tribe v. Florida (1996), the Court held that Congress cannot use its Article I powers to subject non-consenting states to lawsuits in federal court. Though based on Article I, the case paved the way for limiting Congress’s enforcement power under Section 5 of the 14th Amendment in later cases like Boerne v. Flores. It signaled the Court’s revival of state sovereign immunity doctrine.

WRONG! Alden v. Maine (1999) extended sovereign immunity to state courts, not federal, and followed Seminole Tribe rather than being the first to set this limit.

WRONG! Garcia v. San Antonio MTA (1985) was about federalism and the Fair Labor Standards Act, but it upheld federal authority and did not involve sovereign immunity or Section 5 limits.

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