Lockerty v. Phillips
1943 U.S. LEXIS 680, 319 U.S. 182, 63 S. Ct. 1019 (1943)
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Rule of Law:
Congress has the constitutional power under Article III to grant a specialized court exclusive jurisdiction to review administrative regulations and to strip all other federal and state courts of jurisdiction to enjoin the enforcement of those regulations.
Facts:
- During World War II, Congress passed the Emergency Price Control Act of 1942 to combat inflation.
- Pursuant to the Act, the Price Administrator promulgated Maximum Price Regulation No. 169, which fixed maximum wholesale prices for specified cuts of beef.
- Lockerty and other wholesale meat dealers (appellants) alleged that the price ceilings were set so low that they could not purchase meat from packers and resell it to retailers at a profit.
- The wholesalers claimed that enforcement of the regulation would effectively force them out of business.
- The Act established an exclusive procedure for challenging regulations: first, a protest filed with the Administrator, and if denied, a complaint filed with a newly created Emergency Court of Appeals.
- Lockerty and the other dealers did not follow this statutorily prescribed protest and review procedure.
Procedural Posture:
- Lockerty and other wholesale meat dealers (appellants) filed suit against Phillips, the U.S. Attorney for the District of New Jersey (appellee), in the U.S. District Court for the District of New Jersey.
- The suit sought an injunction to restrain the U.S. Attorney from prosecuting them for violations of Maximum Price Regulation No. 169.
- A three-judge panel of the district court was convened to hear the case.
- The district court dismissed the suit for want of jurisdiction, finding that the Emergency Price Control Act explicitly removed its power to grant such an injunction.
- The wholesalers filed a direct appeal to the Supreme Court of the United States.
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Issue:
Does Section 204(d) of the Emergency Price Control Act, which removes jurisdiction from federal district courts to enjoin enforcement of the Act's price regulations and vests that power exclusively in a specialized Emergency Court of Appeals, constitute a valid exercise of congressional power?
Opinions:
Majority - Chief Justice Stone
Yes. The statutory provision removing jurisdiction from the district court is a valid exercise of congressional power. Under Article III of the Constitution, Congress has the sole authority to 'ordain and establish' inferior federal courts, which includes the power to grant, limit, or withhold jurisdiction from them as it sees fit. There is no constitutional requirement for Congress to confer equity jurisdiction on any particular inferior court. The Act does not deny judicial review altogether but instead channels it through a specific and exclusive statutory scheme—the Emergency Court of Appeals—which is a permissible legislative choice.
Analysis:
This decision is a cornerstone of federal courts and administrative law, strongly affirming the doctrine of 'jurisdiction stripping.' It establishes that Congress has broad power to control the jurisdiction of the lower federal courts it creates. The ruling validates the creation of specialized courts to handle complex regulatory schemes, ensuring uniformity and expert adjudication. It also reinforces the principle that litigants must exhaust prescribed administrative and judicial remedies before seeking relief in a court of general jurisdiction.
