In the case of Edelman, Director, Department of Public Aid of Illinois v. Jordan (1973), the U.S. Supreme Court ruled that federal courts cannot order state officials to pay retroactive welfare benefits from a state's treasury as it would violate the Eleventh Amendment’s sovereign immunity clause. The plaintiffs were a group of aged, blind or disabled persons who claimed they had been wrongfully denied timely determination and payment for their applications for federal-state assistance programs by Illinois' Department of Public Aid. While the court upheld an injunction requiring future compliance with federally mandated timelines for processing such claims, it held that ordering back payments constituted an awarding damages against a state which was not permissible under Ex parte Young doctrine - this doctrine allows suits challenging constitutionality of official conduct but does not permit retroactive monetary relief payable from states’ treasuries.

In the dissenting opinion for Edelman v. Jordan, Justice William O. Douglas argued that the majority's decision was a departure from precedent and an unnecessary limitation on federal power to enforce constitutional rights against state officials. He contended that sovereign immunity should not protect states from lawsuits seeking retroactive benefits because such suits are essentially claims against individual officers acting unconstitutionally, rather than direct claims against the state itself. Furthermore, he believed that this interpretation of sovereign immunity would allow states to violate federal law without consequence by simply refusing to comply until sued in each individual case - a process which could take years and deny claimants their rightful benefits during this time period.