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United States v. Johnson

Supreme Court of the United States
319 U.S. 302, 63 S. Ct. 1075 (1943)
ELI5:

Rule of Law:

Federal courts lack jurisdiction to adjudicate a case that is collusive and lacks a genuine adversary issue between the parties, particularly when the constitutionality of a federal statute is challenged.


Facts:

  • One Roach was a tenant in a residential property owned by the appellee (landlord).
  • The property was located in a 'defense rental area' established under the Emergency Price Control Act of 1942, which regulated maximum rent.
  • At the appellee's request, Roach instituted a 'friendly suit' against the appellee to challenge the Act's constitutionality.
  • Roach brought the suit in a fictitious name.
  • Roach did not employ, pay, or meet the attorney who appeared on his behalf; this attorney was procured by the appellee's counsel.
  • The appellee assured Roach that he would incur no expenses from the lawsuit.
  • Roach did not read the complaint filed in his name and was unaware of the specific relief requested (treble damages) until reading about it in a newspaper.

Procedural Posture:

  • Roach, the plaintiff, filed suit against his landlord (appellee) in U.S. District Court, seeking treble damages for rent overcharges under the Emergency Price Control Act of 1942.
  • The appellee moved to dismiss the complaint, challenging the constitutionality of the Act.
  • The United States government intervened to defend the Act's constitutionality.
  • The government moved to dismiss the suit as collusive, but the District Court denied this motion.
  • The District Court granted the appellee's motion and dismissed the complaint, ruling that the Act was an unconstitutional delegation of legislative power.
  • The United States government, as an intervenor, appealed the District Court's decision on constitutionality and its refusal to dismiss for collusion directly to the U.S. Supreme Court.

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Issue:

Does a lawsuit challenging the constitutionality of a federal statute present a justiciable case or controversy when it is a 'friendly suit' initiated at the defendant's request, where the defendant's attorney selects and pays for the plaintiff's attorney, and the plaintiff has no active control over or financial stake in the litigation?


Opinions:

Majority - Per Curiam

No. A lawsuit does not present a justiciable case or controversy when it is a friendly, collusive suit lacking a genuine adversary issue between the parties. The court reasoned that this suit was not a real adversary proceeding because it lacked the 'honest and actual antagonistic assertion of rights' essential to the judicial process. The plaintiff had no active participation, exercised no control, and bore no expense in the litigation. The defendant, through his attorney, dominated the entire proceeding by selecting counsel for the plaintiff and orchestrating the lawsuit. The court held that such a collusive suit, where the public interest in the validity of an Act of Congress is at stake, cannot be adjudicated. Therefore, the integrity of the judicial process requires the court to dismiss the case upon discovering its collusive nature.



Analysis:

This case is a foundational example of the 'case or controversy' requirement under Article III of the Constitution, which bars federal courts from hearing collusive suits or issuing advisory opinions. The Court's decision reinforces the justiciability doctrine that genuine adversity between litigants is a prerequisite for judicial review. It establishes that this safeguard is especially critical when constitutional questions are at stake, preventing parties from manufacturing 'test cases' to challenge laws without a true underlying dispute. The ruling serves as a strong precedent against using the judiciary to resolve abstract or engineered legal questions, ensuring that courts only exercise their power in the context of a real, concrete conflict.

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