the federal courts, allowed lawsuits "between a State and Citizens of another State" as the text reads. In 1795, the Eleventh Amendment was ratified in response to this ruling, removing federal judicial jurisdiction from lawsuits "prosecuted against one of the United States by Citizens of another State, or by Citizens or Subjects of any Foreign State". The validity and retroactivity of the Eleventh Amendment was affirmed in the 1798 case Hollingsworth v. Virginia. Later interpretation In Hans v. Louisiana, the Supreme Court of the United States held that the Eleventh Amendment re-affirms that states possess sovereign immunity and are therefore immune from being sued in federal court without their consent. In later cases, the Supreme Court has strengthened state sovereign immunity considerably. In Blatchford v. Native Village of Noatak, the court explained that (Citations omitted). In Alden v. Maine, the Court explained that while it has Writing for the court in Alden, Justice Anthony Kennedy argued that in view of this, and given the limited nature of congressional power delegated by the original unamended Constitution, the court could not "conclude that the specific Article I powers delegated to Congress necessarily include, by virtue of the Necessary and Proper Clause or otherwise, the incidental authority to subject the States to private suits as a means of achieving objectives otherwise within the scope of the enumerated powers." Sovereign immunity as interpreted by the Supreme Court in Alden v. Maine means a constitutional prohibition of suits against states by its own citizens in state courts and federal courts. However, a "consequence of [the] Court's recognition of pre-ratification sovereignty as the source of immunity from suit is that only States and arms of the State possess immunity from suits authorized by federal law." Northern Ins. Co. of N. Y. v. Chatham County (emphases added). Thus, cities and municipalities lack sovereign immunity, Jinks v. Richland County, and counties are not generally considered to have sovereign immunity, even when they "exercise a 'slice of state power.'" Lake Country Estates, Inc. v. Tahoe Regional Planning Agency. Separately, sovereign immunity of a state from lawsuits in other states have been in question. The Supreme Court ruled in Nevada v. Hall (1977) that states are not constitutionally immune from being named in lawsuits filed in other states. In the intervening years, many states developed legislation that recognize sovereign immunity of other states; since 1979, there had only been 14