the case. Under Article III, Section 2 of the United States Constitution, the Supreme Court of the United States has original jurisdiction over cases between states. Congress, if it so chooses, may grant lower federal courts concurrent jurisdiction over cases between states. However, Congress has not yet chosen to do so. Thus, the United States Supreme Court currently has original and exclusive jurisdiction over cases between state governments. Suits filed against state officials under the "stripping doctrine" The "stripping doctrine" permits a state official who used his or her position to act illegally to be sued in his or her individual capacity. However, the government itself is still immune from being sued through respondeat superior. The courts have called this "stripping doctrine" a legal fiction. Therefore, a claimant may sue an official under this "stripping doctrine" and get around any sovereign immunity that that official might have held with his or her position. When a claimant uses this exception, the state cannot be included in the suit; instead, the name of the individual defendant is listed. The claimant cannot seek damages from the state, because the claimant cannot list the state as a party. The claimant can seek prospective, or future, relief by asking the court to direct the future behavior of the official. For example, Ex parte Young allows federal courts to enjoin the enforcement of unconstitutional state (or federal) statutes on the theory that "immunity does not extend to a person who acts for the state, but [who] acts unconstitutionally, because the state is powerless to authorize the person to act in violation of the Constitution." Althouse, Tapping the State Court Resource, 44 Vand. L. Rev. 953, 973 (1991). Pennhurst State School and Hospital v. Halderman (465 U.S.) ("the authority-stripping theory of Young is a fiction that has been narrowly construed"); Idaho v. Coeur d'Alene Tribe of Idaho ("Young rests on a fictional distinction between the official and the State"). The Young doctrine was narrowed by the court in Edelman v. Jordan, which held that relief under Young can only be for prospective, rather than retrospective, relief; the court reasoned that the Eleventh Amendment's protection of state sovereignty requires the state's coffers to be shielded from suit. Prospective relief includes injunctions and other equitable orders, but would rarely include damages. This limitation of the Young doctrine "focused attention on the need to abrogate sovereign immunity, which led to