vernment corporations of the State are not immune
when suable under the law which created them.[10] Meantime other cases
have expanded the prohibitions of the amendment to include suits brought
against a State by its own citizens,[11] by a foreign state,[12] by a
federally chartered corporation,[13] or by a State as an agent of its
citizens to collect debts owed them by another State.[14] These rulings
are based on the premise expressed in Hans _v._ Louisiana[15] that the
amendment "actually reversed the decision" in Chisholm _v._ Georgia and,
as Chief Justice Hughes indicated in Monaco _v._ Mississippi,[16] had
the effect of prohibiting any suit against a State without its consent
except when brought by the United States[17] or another State.

Suits Against State Officials: Two Categories

Most of the cases involving the Eleventh Amendment and those creating
the greatest difficulties are suits brought against State officials.
Such suits are governed by the same rules and principles as pertain to
the immunity of the United States itself from suits,[18] with the result
that the rules of governmental immunity from suit generally are grounded
on decisions arising under both article III and the Eleventh Amendment
without distinction as to whether a suit is against the United States or
a State.[19] The line is not always easy to draw, nor are the cases
always strictly consistent. They do yield, however, to the formulation
of certain general rules. Thus, suits brought against State officials
acting either in excess of their statutory authority[20] or in pursuance
of an unconstitutional statute[21] are suits against the officer in his
individual capacity and therefore are not prohibited by the Eleventh
Amendment; and suits against an officer for the commission of a common
law tort alleged to be justified by a statute or administrative order of
the State belong to the same category.[22] On the other hand, suits
against the officers of a State involving what is conceded to be State
property or suits asking for relief which clearly call for the exercise
of official authority cannot be sustained.[23]

Mandamus Proceedings

Thus mandamus proceedings which seek "affirmative official action" on
the part of State officials as "the performance of an obligation which
belongs to the State in its political capacity"[24] are uniformly
regarded as suits against the State. This rule is well illustrated by
Louisiana ex rel. Elliott _v.