Eleventh Amendment sovereign immunity; Whether the Ex parte Young doctrine barred plaintiffs’ case for equitable & prospective relief; Virginia Office for Prot. & Advocacy v Stewart; Westside Mothers v Haveman; Whether the suit was barred because it is the functional equivalent of a quiet title action against the State; Idaho v Coeur d’Alene Tribe of Idaho; Whether the suit sought specific performance of a State of Michigan easement contract

[This appeal was from the WD-MI.] The court found that the district court properly denied defendants-state officials’ motion to dismiss based on sovereign immunity, holding that plaintiff-Enbridge’s request for declaratory and injunctive relief to prohibit interference with the operation of its Mackinac pipeline fell within the Ex parte Young exception to Eleventh Amendment sovereign immunity. Enbridge brought this federal action against Governor Whitmer and the Director of the Michigan Department of Natural Resources alleging that their threat to revoke Enbridge’s pipeline easement at the Straits of Mackinac over environmental concerns violates federal law. Plaintiffs requested a declaratory judgment and an injunction prohibiting any interference with the operation of the pipeline. The district court ruled that Enbridge’s action fell under the Ex parte Young doctrine, which provides that suits for equitable and prospective relief for a constitutional or federal violation against a named state official are not “suit[s] against the state,” and not barred by sovereign immunity. Defendants argued that an exception to the doctrine applied because the case was actually “the functional equivalent of a quiet title action against the State and would unduly infringe on the State’s sovereignty interests in its submerged bottomlands.” However, the court noted that Enbridge was only seeking injunctive and declaratory relief to prevent alleged interference and “would not deprive the state of ‘substantially all benefits of ownership and control’ over the State’s submerged lands.” The court also rejected defendants’ argument that the suit was barred because it seeks “specific performance” of a State of Michigan easement contract, thus falling outside of Young. It found that Enbridge did not bring a “contract claim at all.” Instead, it asserted “the efforts of the defendants (individual state officers) to stop the operation of the pipeline violate federal law and the Constitution. And Enbridge requests a quintessential Young injunction prohibiting the defendants from violating federal law.” Affirmed.