limitation on a federal court’s federal-question jurisdiction. The real interests served by the Eleventh Amendment are not to be sacrificed to elementary mechanics of captions and pleading. Application of the Young exception must reflect a proper understanding of its role in our federal system and respect for state courts instead of a reflexive reliance on an obvious fiction.
Idaho v. Coeur d’Alene Tribe of Idaho, 521 U.S. 261, 270 (1997). Further, “the theory of Young has not been provided an expansive interpretation.” Pennhurst State Sch. & Hosp., 465 U.S. at 102. “‘In determining whether the doctrine of Ex parte Young avoids an Eleventh Amendment bar to suit, a court need only conduct a straightforward inquiry into whether [the] complaint alleges an ongoing violation of federal law and seeks relief properly characterized as prospective.’” Verizon Md., Inc. v. Pub. Serv. Comm’n, 535 U.S. 635, 645 (2002) (quoting Coeur d’Alene Tribe of Idaho, 521 U.S. 296 (O’Connor, J., concurring)).
Ex parte Young does not apply, however, to state law claims against state officials, regardless of the relief sought. Pennhurst State Sch. & Hosp., 465 U.S. at 106 (“A federal court’s grant of relief against state officials on the basis of state law, whether prospective or retroactive, does not vindicate the supreme authority of federal law. On the contrary, it is difficult to think of a greater intrusion on state sovereignty than when a federal court instructs state officials on how to conform their conduct to state law.”); see also In re Ohio Execution Protocol Litig., 709 F. App’x 779, 787 (6th Cir. 2017) (“If the plaintiff sues a state official under state law
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