Atlantic Coastline Railroad Co. v. Brotherhood of Locomotive Engineers

1970

Venue: SCOTUS

Facts: Ridiculously complicated. Union picketing of railroad facilities, lots of complexities.

Posture: A ton of different stuff not even included in the edited case... basically battling rulings by state and federal courts. The feds say the union can picket, and the state tries to circumvent that.

Issue: Can federal courts enjoin state courts when state proceedings interfere with federal rights?

Holding: No.

Rule: Lower federal courts possess no power to sit in review of state court decisions.

Reasoning: The Anti Injunction Act doesn't contain an exception for this sort of federal court action. When the state court has concurrent jurisdiction, the federal court isn't free to prevent a party from pursuing claims there (and vice-versa). Any doubts on this point should be resolved in favor of letting the state courts settle the controversy.

Dicta: Brennan (dissenting): The nonintervention policy is hardly absolute, as the exceptions described in the Act make clear. And so state proceedings shouldn't be allowed to undermine a prior judgment of a federal court, and that's what is happening here.