• Last updated on November 11, 2022

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.Eleventh Amendment;Young, Ex parte[Young, Ex parte]

By an 8-1 vote, the Court upheld the injunction. Justice Rufus W. Peckham’sPeckham, Rufus W.;Young, Ex parte[Young, Ex parte] opinion for the majority justified the federal court’s action by creating a legal fiction. If the officer was enforcing an unconstitutional statute, the officer was not acting in his official capacity but was a private individual misusing the state’s authority for his own purposes. The lone dissenter, Justice John Marshall Harlan argued that the majority’s ruling would “practically obliterate the Eleventh Amendment.” Ironically, the Court subsequently determined, in Simpson v. Shepard[case]Simpson v. Shepard[Simpson v. Shepard] (1913), that the 1907 law was constitutional, which meant that Young had not been acting illegally after all.

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.

Eleventh Amendment


Lower federal courts

States’ rights and state sovereignty

Categories: History