| Venue: | SCOTUS |
| Facts: | MN has some statutes setting maximum rates that railroads can charge for passenger and freight; the rates are really low and the penalties for non-compliance are extreme. RR shareholders are sad from this. Young is the attorney general of MN. |
| Posture: | Suit in federal court to enjoin enforcement of the statutes because they violate 14A. TRO granted, but Young proceeds. He's held in contempt, even though Young argues that 11A bars this suit. Young petitions for habeas corpus. |
| Issue: | Is there a remedy in federal court for this sort of violation of the constitution? |
| Holding: | Denied. |
| Rule: | You can sue when a state official takes an illegal act; the state doesn't have the authority to undertake an unconstitutional act and therefore can't authorize its officer to do so. |
| Reasoning: | The constitution is supreme, and the state can't impart immunity to
its officials. Also, we don't want to force people to wait until
they are penalized for non-compliance before they can test the
constitutionality of a statute. And federal courts are the right
place to sort this out.
NB: this is also an exception to the anti-injunction act (see Younger v. Harris, because the federal court is ordering the state DA not to proceed with these prosecutions |
| Dicta: | Harlan (dissenting): This is fiction-- Young was acting in his capacity
as attorney general, and a state can never appear in court except
in the person of its officers.
We owe the states more respect than this-- we're not their supervisors. We need to assume they'll enforce the constitution. 14A doesn't modify 11A. We can't allow litigants to evade the constitution by artful construction, no matter how sympathetic we might feel about them. |