Tennessee Student Assistance Corporation v. Hood

In Tennessee Student Assistance Corporation v. Hood, 541 U.S. 440 (2004), the U.S. Supreme Court upheld the application of the Bankruptcy Code to proceedings initiated by a debtor against a state agency to determine the dischargeability of a student loan debt. Id. at 451. The Court accepted the argument that the Bankruptcy Clause gives Congress the authority to abrogate States' immunity from private suits. See id. at 443.

Chief Justice William Rehnquist wrote this opinion for a 7-2 Court, probably siding with the majority in order to narrow the scope of the ruling. The question presented to the Court was whether Congress has the authority to abrogate state sovereign immunity from private suits. In a very narrow opinion, Chief Justice Rehnquist held that a proceeding initiated by a debtor to determine the dischargeability of a student loan debt is not a suit against the State for purposes of the Eleventh Amendment, and he thereby avoided reaching the question on which certiorari was granted.

The Court later extended this holding in ruling against sovereign immunity in the bankruptcy context in Cent. Va. Cmty. College v. Katz, 546 U.S. 356 (2006).