—the Court held that the Eleventh Amendment does not bar suit against counties in federal court, noting that the "Eleventh Amendment limits the jurisdiction [of the federal courts] only as to suits against a State."

"Eleventh Amendment immunity does not extend to independent political subdivisions created by the State, such as counties and cities."

It has long been the law that the Eleventh Amendment does not bar suits in federal court against political subdivisions of the state.

"While a county is territorially a part of the State, yet politically it is also a corporation, created by and with such powers as are given to it by the State. In this respect it is a part of the State only in that remote sense in which any city, town, or other municipal corporation may be said to be a part."

However, the immunity of the Eleventh Amendment does not extend to suits against counties, municipal corporations, or other of a state's political subdivisions.

This is quite true, but the Eleventh Amendment does not extend its immunity to units of local government.

—holding that Eleventh Amendment immunity does not extend to counties, cities, or municipal corporations

—holding that the Eleventh Amendment does not bar a suit against a county, though the principle advanced has changed over time

The Eleventh Amendment limits the jurisdiction of federal courts only in respect to those cases in which the state is a real party in interest.

The municipality of San Juan is a political subdivision of the Commonwealth, and it has long been clear that municipalities, counties, and similar political subdivisions do not share their states' eleventh amendment immunity.