In the case of John H. Alden, et al. v. Maine in 1998, the U.S Supreme Court ruled that state governments have sovereign immunity from lawsuits brought by their own employees under federal law in state courts without their consent, even if those suits are based on federal labor laws such as Fair Labor Standards Act (FLSA). The court held that Congress does not have authority to abrogate states' Eleventh Amendment immunity using its Article I powers and therefore cannot subject non-consenting states to private suits for damages in their own courts. This decision was a significant affirmation of the principle of state sovereignty and limited the power of federal government over states.

The dissenting opinion in the case of John H. Alden, et al. v. Maine disagreed with the majority's interpretation of state sovereign immunity under the 11th Amendment and its application to federal laws enacted under Article I of the Constitution. The dissent argued that when states joined the Union, they surrendered a portion of their sovereignty, including immunity from lawsuits brought by individuals in federal court for violations of federally protected rights. They contended that this was not an infringement on state sovereignty but rather a necessary part of maintaining supremacy and uniformity in federal law across all states. Furthermore, they believed Congress had clear authority to subject non-consenting states to private suits as it deemed appropriate while exercising its constitutional powers granted by Article I.