Case Citator › Ex Parte Young

Ex Parte Young

Is it still good law? What later courts have actually done to this case.

Limited by some courts
Court
Supreme Court of the United States
Citation
209 U.S. 123
Decided
Confirmed treatments
4
Flagged citations read
1,133 of 1,133
Citing cases (total)
9,560
Treatment dates
1996–2020
Limited by some courts
At least one reviewed court has limited this case’s holding to narrower facts or a narrower rule. No reviewed court has overruled it. Ex parte Young remains controlling law, subject to the 4 confirmed limitations listed below. All flagged citations have been reviewed; the other citing opinions positively applied Young, discussed other authorities, reported another court's act, or rejected an adverse argument.
Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

9,560 later cases cite Ex Parte Young; 1,133 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Ex Parte Young?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Limited

  • Young does not permit an officer suit to enforce IGRA's negotiation duty because Congress supplied a detailed remedial scheme.

    Seminole Tribe of Florida v. Florida · Supreme Court of the United States · filed

    The situation presented here, however, is sufficiently different from that giving rise to the traditional Ex parte Young action so as to preclude the availability of that doctrine. ... We hold that Ex parte Young is inapplicable to petitioner’s suit against the Governor of Florida.
    Read the full opinion on CourtListener →

  • Young does not reach relief functionally equivalent to a quiet-title action implicating special state-sovereignty interests.

    Idaho v. Coeur d'Alene Tribe of Idaho · Supreme Court of the United States · filed

    We now turn to consider whether the Tribe may avoid the Eleventh Amendment bar and avail itself of the Young exception. ... this suit, we decide, falls on the Eleventh Amendment side of the line, and Idaho’s sovereign immunity controls.
    Read the full opinion on CourtListener →

  • The court declined to extend Young to an essentially contractual claim against tribal officials merely because declaratory and injunctive relief was requested.

    Douglas Indian Association v. Central Council of Tlingit and Haida Tribes of Alaska · Supreme Court of Alaska · filed

    Douglas requests injunctive relief ordering that the officials “neither take nor permit any action inconsistent” with the court’s declaration that Central Council is Douglas’s trustee or agent, but “Ex parte Young cannot be used to obtain . . . an order for specific performance of a . . . contract.”
    Read the full opinion on CourtListener →

  • The court required a plaintiff seeking prospective relief under Young to name the state official in her individual capacity.

    Avery v. Benson · E.D. Mich. · filed

    Though Ex Parte Young 209 U.S. 123 (1908) provides a mechanism for seeking injunctive relief against state officials sued in their individual capacity, Defendant correctly observes that Plaintiffs do not specify in what capacity they are suing the Secretary of State. ... Because Plaintiffs do not specify that they are suing the Secretary of State in her individual capacity, they cannot circumvent the Eleventh Amendment under Ex Parte Young.
    Read the full opinion on CourtListener →

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