| Venue: | SCOTUS |
| Facts: | Harris is indicted for "criminal syndicalism." Some other plaintiff join because they think this prosecution will inhibit them from promoting the mission of the Progressive Labor Party. And yet another guy who teaches history joins as a plaintiff because he's worried that he won't be ablte to teach Marx. Everybody says they'll suffer immediate and irreparable injury unless the state court is enjoined from proceeding. |
| Posture: | Over a pending criminal suit in state court, plaintiffs sue in federal district court for an injunction to prevent the criminal suit from going forward, on 1A and 14A grounds. District court rules that it has the power to restrain the prosecution, and that the criminal syndicalism act is void for vagueness, and enjoins the DA from further pending action. Appeal, presumably. |
| Issue: | If a state statute looks on its face as though it might be constitutional, may a federal court issue injunctions against its enforcement? |
| Holding: | Not on that basis alone. Reversed and remanded. |
| Rule: | In order to justify intervention, the threat to the plaintiff's federal
rights must be on that can't be eliminated by his defense against
a single criminal prosecution.
Also, people who have only speculative fears of prosecution are not to be accepted as plaintiffs in cases of this sort. |
| Reasoning: | At least Harris has a live controversy-- those other folks don't.
Still, from the start, we've wanted state courts to be able to
try their cases free from interference. The Anti-Injunction Act
has has hardly changed since 1793.
We do have the Ex Parte Young exception for people who will suffer irreparable damages if the state court proceeding is not enjoined. The idea here is that a court of equity should only act to restrain a crominal prosecution when the moving party has no adequate remedy at law and will suffer irreparable harm if no relief issues. The underlying principle here is comity: we have a proper respect for state functions. This is part of federalism, and we hold that dear. It doesn't mean blind deference to States' rights, though: it means that the federal government shouldn't unduly interfere with the legitimate activities of the states. The normal thing to do, though, is not to issue such injunctions. There's no suggestion here that the prosecution of Harris is in bad faith or is only one in a series to which he'll be subjected. Thus, irreparable injury is not by itself sufficient to qualify for relief: all criminals face irreparable injury if convicted. And injunctive relief wouldn't eliminate the alleged chilling effect, either. And the fact that a statute might have a chilling effect doesn't automatically render it unconstitutional. There might be extraordinary circumstances:
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| Dicta: | Brennan (concurring): his constitutional contentions could be adequately addressed in the state proceeding, so federal intervention is improper. |