the title on March 31; and the title transfer was recorded on May 14, 1883. United States v. Lee is one of three important federal sovereign immunity cases, and the most important doctrinally. The case showed just how sharply divided the Supreme Court was over the scope and legitimacy of sovereign immunity in the United States. The majority opinion questioned whether sovereign immunity was appropriate in a republic, and suggested that it had been adopted in an unprincipled and careless way by previous court decisions. The decision was the first to refuse to extend sovereign immunity to officers of the state acting as individuals, a principle which would later become known as the "stripping doctrine". The decision also revised the Supreme Court's "nominal party rule," first enunciated in Osborn and Davis. In those cases, the Court had salvaged federal and state sovereign immunity by creating a bright-line legal fiction that the suits were against government officers in their capacity as individuals and not acting on behalf of the state. The Court in Lee reaffirmed this "nominal party rule" but only with five votes—which proved to be the last time it was invoked. In Louisiana ex rel. Elliot v. Jumel, 107 U.S. 711 (1882), a majority of the Court upheld the "nominal party rule" but refused to invoke it on a technicality. In New Hampshire v. Louisiana, 108 U.S. 76 (1883), the Court abandoned the "nominal party rule" in favor of a "real party interest test." The Court openly rejected the rule (without necessarily overturning its previous decision) in In re Ayers, 123 U.S. 443 (1887). Nevertheless, the Court did not overturn Lee but rather distinguished it narrowly and continued to affirm its basic principles in Jumel and Ayers. United States v. Lee also sharply limited the sovereign immunity doctrine by implying that it could be subordinated to other, more fundamental rights such as the Fifth Amendment's prohibition against "takings" without just compensation and due process. Justice Miller's ringing endorsement of the rights of individuals is seen as endorsing the concept that, in the United States, the people are the sovereign—not the government. In Tindal v. Wesley, 167 U.S. 204 (1897), the Supreme Court expressly extended the Lee decision to "takings" suits against states (which had previously been barred by the Court's constitutional interpretations). Although Lee seemed to invite a full-scale reconsideration of the doctrine of sovereign immunity, subsequent Supreme Court