argued that the monetary sanctions violated § 14. The Supreme Court held: “ ‘Section 14 prohibits actions against state officers in their official capacities when those actions are, in effect, actions against the State. Lyons v. River Road Constr., Inc., 858 So.2d 257, 261 (Ala.2003); Mitchell v. Davis, 598 So.2d 801, 806 (Ala.1992). “In determining whether an action against a state officer or employee is, in fact, one against the State, [a] [c]ourt will consider such factors as the nature of the action and the relief sought.” Phillips v. Thomas, 555 So.2d 81, 83 (Ala.1989). Such factors include whether “a result favorable to the plaintiff w in light of § 14, the commissioner, in his official capacity, may be assessed civil sanctions for his failur 8, 153 So.2d 234, 236 (1963) (<HOLDING>). Thus, we hold that the trial court’s order
holding that  14 prevents an action against the state when a result favorable to the plaintiff would directly affect a contract or property right of the state holding that an action cannot be maintained under young in unique circumstances where the suit against the state officer affects an essential attribute of state sovereignty in a manner that the action must be understood as one against the state holding that a declaratoryjudgment action against the state that would affect property in which the state had an interest was barred by  14 holding that an action against an officer was not an action against the state because the relief sought would not take away any property of the state or fasten a lien on it or interfere with the disposition of funds in the treasury holding a suit against an agency of the state is a suit against the state