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Reviewing that history, law professor John Orth explains there are “two ways to reverse a U.S. Supreme Court decision by constitutional amendment. The first type of amendment may reverse the decision by instructing the Court on the proper construction of a particular provision, as in the case of the Eleventh Amendment.”

But the judge said the Eleventh Amendment “prohibits a federal court from awarding declaratory or injunctive relief of the kind at issue against a state official based only on a violation of state law.”

He added: “But the Eleventh Amendment prohibits a federal court from awarding declaratory or injunctive relief of the kind at issue against a state official based only on a violation of state law.”

Unlike a state official, the sheriff is not entitled to Eleventh Amendment immunity when sued for damages in his official capacity, the court said.

Natural Gas Act does not allow companies to condemn state controlled land in federal court because states enjoy sovereign immunity from such actions under the Eleventh Amendment of the U.S.