_ Jumel[25] where a holder of Louisiana
State bonds sought to compel the State treasurer to apply a sinking fund
that had been created under an earlier constitution for the payment of
the bonds to such purpose after a new constitution had abolished this
provision for retiring the bonds. The proceeding was held to be a suit
against the State because: "The relief asked will require the officers
against whom the process is issued to act contrary to the positive
orders of the supreme political power of the State, whose creatures they
are, and to which they are ultimately responsible in law for what they
do. They must use the public money in the treasury and under their
official control in one way, when the supreme power has directed them to
use it in another, and they must raise more money by taxation when the
same power has declared that it shall not be done."[26] However,
mandamus proceedings to compel a State official to perform a plain or
ministerial duty which admits of no discretion are not suits against the
State since the official is regarded as acting in his individual
capacity in failing to act according to law.[27]

Early Limitation on Injunction Proceedings

In spite of a dictum by Justice Bradley in the McComb Case that the
writs of mandamus and injunction are somewhat correlative to each other
in suits against State officials for illegal actions,[28] injunctions
against State officials to restrain the enforcement of an
unconstitutional statute or action in excess of statutory authority are
more readily obtainable. They constitute in fact the single largest
class of cases involving the issue of State immunity. Until Reagan _v._
Farmers' Loan and Trust Company[29] the Court maintained a distinction
between the duty imposed upon an official by the general laws of the
State and the duty imposed by a specific unconstitutional statute and
held that whereas an injunction would not lie to restrain a State
official from enforcing an act alleged to be unconstitutional in
pursuance of the general duties of his office, it would lie to restrain
him from performing special duties vested in him by an unconstitutional
statute.[30] The leading cases assertive of this distinction are Ex
parte Ayers and Fitts _v._ McGhee, decided respectively in 1887 and
1899.[31]

Injunction Proceedings Today: Ex parte Young

However, the distinction between injunction suits to restrain an
official from pursuing his general duties under