## Facts

- Chatham County, Georgia owned, operated, and maintained the Causton Bluff Bridge, a drawbridge over the Wilmington River.
- A boat piloted by James K. Ludwig, Jr. requested a bridge opening; the bridge malfunctioned and a section fell onto the boat, causing more than \$130,000 in damage.
- The boat owners’ marine insurer paid the loss and, as subrogee, filed an in personam admiralty action in federal district court alleging negligent operation of the drawbridge by county employees.
- Chatham County moved for summary judgment, conceding it was not entitled to Eleventh Amendment immunity as a county but asserting a broader sovereign immunity based on state-delegated authority and a “universal” immunity rule.
- The district court granted summary judgment for the County, and the Eleventh Circuit affirmed.

## Issues

1. Whether a county that is not an “arm of the State” for Eleventh Amendment purposes may nevertheless assert state sovereign immunity to bar a federal in personam admiralty suit authorized by federal law.

## Decision

- The Supreme Court unanimously reversed.
- Because Chatham County was not an arm of the State, it could not invoke Eleventh Amendment immunity.
- The Court rejected the County’s claim to a separate, non–Eleventh Amendment “universal” sovereign immunity for political subdivisions in admiralty.
- The case was remanded for further proceedings on the merits of the admiralty negligence claim.

## Legal Principles

- In federal court, state sovereign immunity is analyzed through the Eleventh Amendment framework; immunity generally extends only to States and entities that qualify as an “arm of the State.”
- Political subdivisions such as counties and municipalities do not receive Eleventh Amendment immunity unless they meet the arm-of-the-State criteria.
- Federal law governs the availability and scope of immunity in federal admiralty proceedings; state-law characterizations or delegations of authority cannot create federal-court sovereign immunity for a non-arm-of-the-State county.
- Admiralty jurisdiction does not supply an independent basis for extending sovereign immunity to counties that fall outside Eleventh Amendment protection.

## Conclusion

The Court held that a county cannot avoid a federally authorized admiralty in personam suit by asserting a residual, state-derived sovereign immunity when it is not an arm of the State under Eleventh Amendment doctrine.


N. Ins. Co. of N.Y. v. Chatham Cnty., 547 U.S. 189 (2006)