Northern Ins. Co. of N. Y. v. Chatham County, 547 U.S. 189 (2006)

In the case of Northern Ins. Co. of N. Y. v. Chatham County, the underlying dispute arose from an incident on October 6, 2002, involving the Causton Bluff Bridge, a drawbridge owned and operated by Chatham County, Georgia. James Ludwig requested the bridge to be raised to allow his boat to pass; however, the bridge malfunctioned, resulting in a portion of it falling and colliding with Ludwig's boat. The collision caused damages exceeding $130,000 to Ludwig and his wife. They submitted a claim to their insurer, Northern Insurance Company of New York, which paid the claim according to their policy terms. Subsequently, Northern sought to recover its costs by filing a suit in admiralty against Chatham County. The procedural history of the case began when Northern filed its lawsuit in the United States District Court for the Southern District of Georgia. Chatham County moved for summary judgment, asserting that Northern's claims were barred by sovereign immunity. Although the County acknowledged that Eleventh Amendment immunity did not apply to counties, it argued that it was protected under a broader principle of state immunity from lawsuits without the state's consent. The District Court granted the County's motion for summary judgment, citing precedent that sovereign immunity extends to counties exercising powers delegated by the state. The Eleventh Circuit Court of Appeals affirmed this decision, adhering to Circuit precedent, and concluded that while the County did not qualify as an arm of the state for Eleventh Amendment purposes, it still enjoyed a form of common law immunity. The relevant background context includes the established principle that states possess sovereign immunity, which has been recognized as a fundamental aspect of state sovereignty since before the Constitution's ratification. This case raised the question of whether a political subdivision, like Chatham County, could assert sovereign immunity in an admiralty suit despite not being considered an arm of the state under the Eleventh Amendment. The Supreme Court granted certiorari to address this issue, following the Eleventh Circuit's affirmation of the District Court's ruling.

Whether an entity that does not qualify as an "arm of the State" for Eleventh Amendment purposes can nonetheless assert sovereign immunity as a defense to an admiralty suit.

The judgment of the Court of Appeals is reversed.