Nevada v. Hall
1979 U.S. LEXIS 69, 440 U.S. 410, 59 L. Ed. 2d 416 (1979)
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Rule of Law:
The U.S. Constitution does not grant states sovereign immunity from suit in the courts of another state. A state may, as a matter of comity, afford immunity to a sister state, but it is not constitutionally compelled to do so and may prioritize its own public policy, such as providing full compensation for injuries occurring within its borders.
Facts:
- On May 13, 1968, California residents suffered severe injuries in an automobile collision on a California highway.
- The driver of the other vehicle was an employee of the University of Nevada, an instrumentality of the State of Nevada.
- The Nevada employee was driving a car owned by the State of Nevada while engaged in official business.
- The Nevada state employee was killed in the collision.
- A Nevada statute limits any tort award against the state to a maximum of $25,000.
- One of the California residents, a minor, sustained permanent brain damage, leaving him severely retarded, while his mother suffered severe physical and emotional injuries.
Procedural Posture:
- California residents (respondents) filed a tort suit against the State of Nevada and others in the Superior Court of San Francisco, a California state trial court.
- The trial court granted Nevada's motion to quash service of process.
- A California appellate court reversed the trial court's order.
- The California Supreme Court affirmed, holding Nevada was amenable to suit in California courts.
- The U.S. Supreme Court denied Nevada's initial petition for a writ of certiorari.
- On remand to the trial court, Nevada moved to limit damages to its statutory cap of $25,000, arguing the Full Faith and Credit Clause required it.
- The trial court denied Nevada's motion to limit damages.
- A jury returned a verdict for the respondents for $1,150,000, and the trial court entered judgment.
- The California Court of Appeal affirmed the judgment.
- The California Supreme Court denied review.
- The State of Nevada successfully petitioned the U.S. Supreme Court for a writ of certiorari to review the judgment.
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Issue:
Does the U.S. Constitution, under either the Full Faith and Credit Clause or an implicit principle of state sovereign immunity, prohibit a state court from exercising jurisdiction over a non-consenting sister state and from refusing to apply that state's statutory limitation on damages?
Opinions:
Majority - Mr. Justice Stevens
No. The Constitution does not prohibit a state court from exercising jurisdiction over a sister state or require it to apply the sister state's liability limitations. Immunity of a sovereign in the courts of another sovereign has historically been a matter of voluntary comity, not a constitutional right. The Full Faith and Credit Clause does not compel a state to apply another state's law in violation of its own legitimate public policy. California has a substantial interest in providing full protection and compensation for individuals injured on its highways by both residents and nonresidents, and enforcing Nevada's damage cap would be 'obnoxious' to this policy. The Eleventh Amendment and the debates surrounding it pertained to immunity in federal courts, not in the courts of other states, and no other constitutional provision implicitly creates such an interstate immunity.
Dissenting - Mr. Justice Blackmun
Yes. The judgment should be reversed because the Constitution implicitly guarantees interstate sovereign immunity as an essential component of federalism. While not explicitly mentioned, this immunity was a universally accepted principle at the time of the framing, and its existence is necessary to prevent interstate retaliation and preserve our system of cooperative federalism. Just as the Court has recognized implied rights like the right to travel, it should recognize this fundamental aspect of sovereignty. The Eleventh Amendment's ban on suing states in federal court would be illogical if the Framers intended to leave states vulnerable to suit in the potentially more biased courts of sister states.
Dissenting - Mr. Justice Rehnquist
Yes. The judgment should be reversed because the constitutional plan is built on tacit postulates, including the principle that unconsenting states are immune from suit in the courts of sister states. The Framers, including Madison, Marshall, and Hamilton, assured that state sovereign immunity would remain intact, and the Eleventh Amendment was enacted to restore this understanding after the Chisholm decision. Allowing a state to be sued in another state's court undermines the logic of federalism, which established neutral federal forums for interstate disputes, and makes a mockery of the protections the Eleventh Amendment was intended to provide. This decision disrupts the parity between states and works a fundamental readjustment of their relationships.
Analysis:
This decision establishes that interstate sovereign immunity is not a constitutional mandate but rather a principle of comity that a state is free to accept or reject. By allowing a forum state's public policy to override a defendant state's sovereign immunity and statutory damage caps, the ruling significantly empowers states to protect their own residents and regulate conduct within their borders. This creates a notable exception to the traditional doctrine of sovereign immunity, potentially increasing litigation against states for their extraterritorial activities and forcing states to consider their potential liability under the laws of all other states where their agents may act.
