Cameron v. Johnson
1968 U.S. LEXIS 1879, 390 U.S. 611, 20 L. Ed. 2d 182 (1968)
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Rule of Law:
Federal courts should not enjoin good-faith state criminal prosecutions brought under a valid, narrowly drawn statute, even if such enforcement has an incidental chilling effect on First Amendment rights. An injunction is only justified upon a showing of 'special circumstances,' such as bad-faith enforcement intended to harass and discourage protected activities with no expectation of obtaining a valid conviction.
Facts:
- On January 22, 1964, civil rights organizations began picketing the Forrest County courthouse in Hattiesburg, Mississippi, to protest racial discrimination in voter registration.
- Shortly after the protests began, the county sheriff designated a specific 'march route' on the courthouse grounds for the picketers.
- The picketing continued peacefully on this designated route every day, except Sundays, for over two months until April 9, 1964.
- On April 8, 1964, the Mississippi Legislature enacted the Anti-Picketing Law, which made it illegal to picket in a manner that obstructs or unreasonably interferes with access to courthouses.
- The next day, April 9, the sheriff read the new law to the picketers and removed the barricades that had marked the 'march route.'
- On April 10, when about 35-40 people resumed picketing along the now-unmarked route, they were arrested for violating the new statute, with more arrests occurring that afternoon and the next day.
- Picketing continued daily from April 11 until May 18 without any arrests.
- On May 18, nine more picketers were arrested, after which all picketing at the courthouse ceased.
Procedural Posture:
- Appellants (picketers) filed suit in the U.S. District Court for the Southern District of Mississippi against state officials, seeking to declare the Mississippi Anti-Picketing Law unconstitutional and enjoin its enforcement.
- A three-judge District Court initially dismissed the complaint based on the doctrine of abstention.
- The U.S. Supreme Court vacated the dismissal and remanded the case, instructing the District Court to reconsider it in light of Dombrowski v. Pfister.
- On remand, the District Court held an evidentiary hearing, declared the statute constitutional, and again dismissed the complaint with prejudice after finding no grounds for an injunction.
- The appellants then filed a direct appeal of the District Court's dismissal to the U.S. Supreme Court.
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Issue:
Does the good-faith enforcement of a specific, non-vague state anti-picketing statute constitute the 'special circumstances' of irreparable injury required to justify a federal court injunction against pending state criminal proceedings?
Opinions:
Majority - Mr. Justice Brennan
No, the good-faith enforcement of a specific, non-vague anti-picketing statute does not constitute irreparable injury justifying a federal injunction. The Court first held that the Mississippi statute was not unconstitutional on its face. The terms 'obstruct' and 'unreasonably interfere' are words of common understanding, so the statute is not void for vagueness. It is also not overbroad because it regulates conduct (blocking access to a courthouse) rather than pure speech, which is a permissible form of regulation. The Court then held that a federal injunction was not warranted because there was no showing of 'special circumstances' as required by Dombrowski v. Pfister. Federal courts should not interfere with a state's good-faith administration of its criminal laws. The 'chilling effect' that naturally flows from the enforcement of a valid statute is not the kind of irreparable injury that justifies federal intervention. The District Court found that the prosecutions were brought in good faith to enforce the law, not to harass the appellants, and the Supreme Court found no reason to overturn this finding. The fact that arrests were not made for a five-week period suggested the authorities did not believe the statute was being violated during that time, undermining the claim of bad-faith harassment.
Dissenting - Mr. Justice Fortas
Yes, the circumstances here demonstrate bad-faith enforcement that constitutes irreparable injury justifying a federal injunction. While the statute is not unconstitutional on its face, Dombrowski also applies to statutes that are applied in bad faith to discourage protected activities. The dissent argued that the record clearly demonstrated bad faith. For two and a half months, the picketing was peaceful and confined to a police-designated route without incident. The legislature then passed a 'rifle-shot law' aimed directly at this specific protest, and arrests began immediately, even when the picketing was not actually obstructive. This sequence of events shows the state was not engaged in legitimate law enforcement but was executing a deliberate plan to end the demonstration. The dissent concluded that the state had 'no hope of ultimate success' in securing valid convictions, proving that the prosecutions were initiated solely to harass the protesters and suppress their First Amendment rights.
Analysis:
This decision significantly clarified and narrowed the scope of the Dombrowski doctrine, which allowed federal courts to enjoin bad-faith state prosecutions. By distinguishing between the 'chilling effect' of a bad-faith prosecution and the incidental chilling effect of a good-faith prosecution, the Court raised the bar for plaintiffs seeking federal injunctive relief. Cameron v. Johnson reinforces principles of federalism and comity, showing great deference to state criminal proceedings unless there is compelling evidence of a state's improper motive to harass and suppress constitutional rights rather than to enforce its laws. This makes it more difficult for protest groups to halt state-level prosecutions in federal court, requiring them to prove not just that a law impacts their speech, but that it is being enforced illegitimately.
