Seminole Tribe of Florida v. Florida, 517 U.S. 44 (1996), was a United States Supreme Court case which held that Article One of the U.S. Constitution did not give the United States Congress the power to abrogate the sovereign immunity of the states that is further protected under the Eleventh Amendment. Such abrogation is permitted where it is necessary to enforce the rights of citizens guaranteed under the Fourteenth Amendment as per Fitzpatrick v. Bitzer. The case also held that the doctrine of Ex parte Young, which allows state officials to be sued in their official capacity for prospective injunctive relief, was inapplicable under these circumstances, because any remedy was limited to the one that Congress had provided. Background Indian gaming history The Seminole Tribe of Florida owned property in Fort Lauderdale, Florida, seven miles southwest of downtown, and in the late 1970s, built a large bingo facility on that land. As this was before the enactment of the Indian Gaming Regulatory Act, the tribe then sued the Broward County Sheriff in federal court to prevent him from enforcing state law on tribal land. The Southern District of Florida heard the case and issued a preliminary injunction in favor of the tribe in 1979 and a permanent injunction the following year. The sheriff appealed, and the Fifth Circuit affirmed the lower court's decision. That court decision opened the floodgates for Indian gaming, which had been shut down in 1949 by a decision in Wisconsin that Indians could not use slot machines or other gambling instruments on their reservations. Since bingo did not use those prohibited instruments, the tribes were free to open bingo halls. By 1983, about 180 bingo halls were being operated by tribes on reservations across the nation. This prompted a flood of litigation as the individual States attempted to shut down Indian gaming by either civil or criminal cases, efforts which typically failed, as in California. As the various Indian tribes sought to obtain a steady source of revenue through gaming, some tribes went further than others. While abiding with the federal prohibition on gambling machines and instruments, the Puyallaup Indian tribe, on their reservation, opened casinos that offered blackjack, poker, and craps. Federal law enforcement authorities arrested the tribal members operating the casino and charged them with violating the Organized Crime Control Act. Similar results occurred in Michigan with the Lake Superior Band of Chippewa Indians.