Although federal courts had not been allowed to intervene in pending state court proceedings, the Supreme Court held that in extraordinary circumstances, a federal court may issue an injunction ordering state officials not to enforce a state statute until its validity has been decided in court.
A 1907 Minnesota law reduced railroad rates and imposed severe day-to-day penalties for violations. In addition to challenging the reduced rates, the railroads asserted that the day-to-day fines were ruinous, which violated the due process requirements of the Fourteenth Amendment. Therefore, the railroads went to the federal district court to seek a temporary injunction to stop state officials from imposing the fine while the case was being adjudicated. A federal district court issued such an injunction to Edward Young, Minnesota’s attorney general. When Young was jailed for ignoring the order, he petitioned the Supreme Court for a writ of habeas corpus.
By an 8-1 vote, the Court upheld the injunction. Justice Rufus W. Peckham’s
At the time, the Young decision was very unpopular. In 1910 Congress established special three-judge federal courts to handle suits for injunctions against state officers. The Johnson Act of 1934 prohibited most federal injunctions against state regulations of rates. After World War II, federal courts applied the Young doctrine when enjoining state officials from depriving persons of civil rights and civil liberties.
Lower federal courts
States’ rights and state sovereignty