Ex parte Young
209 U.S. 123 (1908)
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Rule of Law:
A suit seeking to enjoin a state official from enforcing a state statute that allegedly violates the U.S. Constitution is not a suit against the state for Eleventh Amendment purposes, because an official acting under an unconstitutional law is stripped of their official authority. Therefore, federal courts have jurisdiction to grant such prospective injunctive relief.
Facts:
- The Minnesota legislature passed laws that drastically lowered the freight and passenger railroad rates within the state.
- These laws imposed severe penalties for any violations, including substantial fines for the railroad companies and felony charges with fines and imprisonment for railroad employees and agents.
- Shareholders of the Northern Pacific Railway Company, including Perkins and Shepard, believed the new rates were confiscatory, meaning so low they would deprive the company of its property without due process of law in violation of the Fourteenth Amendment.
- The shareholders also contended that the extreme penalties effectively deterred the railroad company and its employees from violating the law to challenge its constitutionality in court.
- Edward T. Young, the Attorney General of Minnesota, was bound by his general official duty to enforce the laws of the state, including the new rate acts.
Procedural Posture:
- Stockholders of the Northern Pacific Railway sued Attorney General Young and other officials in the U.S. Circuit Court for the District of Minnesota, seeking to enjoin the enforcement of new state rate laws.
- The Circuit Court granted a temporary injunction that prohibited Young from enforcing the laws.
- In defiance of the federal injunction, Young initiated a mandamus proceeding in a Minnesota state court to compel the railroad to comply with the rate laws.
- The U.S. Circuit Court found Young in contempt for violating its injunction, fined him, and ordered him into the custody of the U.S. Marshal until he dismissed the state-court action.
- Young filed a petition for a writ of habeas corpus directly with the U.S. Supreme Court, arguing that the Circuit Court lacked jurisdiction over him and the contempt order was therefore void.
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Issue:
Does a federal court have jurisdiction to grant an injunction against a state official acting in his official capacity to enforce a state law that is allegedly unconstitutional, or is such a suit barred by the Eleventh Amendment's grant of sovereign immunity to the states?
Opinions:
Majority - Justice Peckham
Yes. A federal court has jurisdiction to grant an injunction against a state official in these circumstances because a suit to restrain a state officer from enforcing an unconstitutional statute is not a suit against the state. The court reasoned that the Eleventh Amendment, which protects a state from being sued in federal court without its consent, does not apply when a state official attempts to enforce a law that violates the U.S. Constitution. When an official acts pursuant to an unconstitutional statute, they are 'stripped of his official or representative character' and are subjected in their person to the consequences of their individual conduct. The state cannot authorize an unconstitutional act, so the officer is not acting on behalf of the state. Furthermore, the penalties for violating the Minnesota acts were so severe as to be unconstitutional on their face because they effectively denied the railroad companies the ability to seek judicial review of the law's validity without facing the risk of confiscatory fines and imprisonment for their employees. An equitable suit for an injunction was the only adequate remedy, as a legal defense in a state prosecution would come too late and at too great a peril.
Dissenting - Justice Harlan
No. The suit against Attorney General Young is, in effect, a suit against the State of Minnesota and is therefore explicitly barred by the Eleventh Amendment. The dissent argued that the majority created a legal fiction to circumvent the clear command of the Constitution. Young was sued only in his official capacity as Attorney General, and the sole purpose of the suit was to prevent the state itself from enforcing its laws in its own courts. A state can only act through its officers; therefore, enjoining the state's chief law officer is the same as enjoining the state. This ruling, Harlan warned, would work a 'radical change in our governmental system' by allowing subordinate federal courts to control the actions of sovereign states. The proper procedure would have been for the railroad to raise its constitutional claims as a defense in the state court proceeding, with the ultimate right to appeal to the U.S. Supreme Court if its federal rights were denied.
Analysis:
This case established the 'Ex parte Young doctrine,' a critical exception to the Eleventh Amendment's sovereign immunity. By creating the legal fiction that a state official is 'stripped' of state authority when attempting to enforce an unconstitutional law, the Court provided a mechanism for private parties to challenge the constitutionality of state laws in federal court. This decision significantly empowered federal courts to enforce the protections of the U.S. Constitution, particularly the Fourteenth Amendment, against the states. Without this doctrine, individuals and corporations would have to violate a potentially unconstitutional state law and raise the law's invalidity as a defense in a state enforcement action, a risky and often inadequate process.
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