The Court, in an opinion by Justice Rehnquist, concluded that private litigants could not avoid the bar of state sovereign immunity by manipulating the doctrine of "Ex parte Young". No case examining state sovereign immunity had held that states could be required to repay funds that had wrongfully been withheld. In almost all the cases that had permitted retrospective recovery against the states, the state had not raised the issue of state sovereign immunity. The Supreme Court also overruled any cases in which the state had raised the issue and lost.