Sterling v. Constantin
53 S. Ct. 190, 1932 U.S. LEXIS 793, 287 U.S. 378 (1932)
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Rule of Law:
A state governor's declaration of martial law does not grant unlimited power or shield their actions from judicial review. Federal courts may enjoin a governor's military orders that deprive individuals of property rights in violation of the Fourteenth Amendment when the orders are not justified by an actual state of war or insurrection where civil courts are unable to function.
Facts:
- Complainants were owners and operators of oil and gas leaseholds in the East Texas oil field.
- The Railroad Commission of Texas, authorized by state law to prevent waste, issued orders limiting the amount of oil that could be produced from wells in the field.
- Governor Ross S. Sterling declared that a 'state of insurrection, tumult, riot, and a breach of the peace' existed in the oil field due to opposition to conservation laws.
- Under this declaration, Governor Sterling proclaimed 'martial law' and deployed the Texas National Guard, commanded by Brigadier General Jacob F. Wolters, to the area.
- After a federal court issued a temporary restraining order against the Railroad Commission's production limits, Governor Sterling issued his own executive and military orders directing General Wolters to enforce nearly identical production limits.
- The evidence established that at no time was there any actual riot, tumult, or insurrection in the territory; the civil courts remained open and were functioning without impediment.
Procedural Posture:
- Complainants sued the members of the Texas Railroad Commission in the U.S. District Court to enjoin the enforcement of oil production limits.
- A federal district judge granted a temporary restraining order against the Commission.
- Complainants then filed an amended bill in the same action, adding Governor Sterling and military officials as defendants to enjoin their military orders enforcing similar limits.
- A specially constituted three-judge District Court heard the application for an injunction against the Governor and his officials.
- The District Court granted an interlocutory injunction restraining the appellants from enforcing their military orders.
- The parties stipulated that the case be submitted for a final judgment on the same evidence, and the District Court entered a final judgment making the injunction permanent.
- The Governor and other officials (appellants) appealed both the interlocutory order and the final judgment to the Supreme Court of the United States.
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Issue:
Does a state governor's declaration of martial law, in the absence of actual war or insurrection, shield their executive orders from judicial review and injunction by a federal court when those orders deprive citizens of their property rights in violation of the Fourteenth Amendment?
Opinions:
Majority - Mr. Chief Justice Hughes
Yes. A state governor's declaration of martial law does not shield their executive orders from judicial review and injunction by a federal court under these circumstances. While the executive has discretion to determine that an exigency requiring military aid has arisen, this discretion is not absolute. The allowable limits of military discretion and whether they have been overstepped are judicial questions. The governor's power to suppress insurrection does not permit the subversion of private rights or the nullification of judicial authority when civil courts are open and functioning. Here, the governor's orders were not a response to violence but an attempt to regulate oil production, a function of civil government, and to override the jurisdiction of a federal court properly examining a constitutional claim. Such an exertion of state power, which deprives individuals of property without due process, is an unconstitutional transgression that the federal judicial power is authorized to prevent.
Analysis:
This case establishes a crucial limit on executive power, affirming that a declaration of martial law is not a blank check to suspend constitutional rights. By subjecting the governor's actions to judicial scrutiny, the Court reinforced the principle of the rule of law and the subordination of the military to civil authority. The decision clarifies that the judiciary has the power and duty to look beyond the executive's proclamation to the factual reality of the situation. This precedent is vital in preventing the use of emergency powers as a pretext for overriding individual liberties or circumventing the judicial process, ensuring that even the highest state executive is accountable to the Constitution.
