Ex Parte Young
Ex Parte Young is a significant legal case from 1907 involving a challenge to a Minnesota law that reduced railroad rates and imposed severe fines for violations. The railroads argued that these fines violated their due process rights under the Fourteenth Amendment. Seeking relief, they obtained a federal district court injunction against Minnesota's attorney general, Edward Young, who subsequently faced jail time for defying the order. The Supreme Court upheld the injunction in an 8-1 decision, articulating a legal principle that allowed federal courts to intervene in state actions when state officials enforce unconstitutional laws. This ruling was contentious, with dissenting opinions cautioning against its implications for state sovereignty under the Eleventh Amendment. The Ex Parte Young decision has had lasting effects, influencing how federal courts address civil rights and state authority. Over the years, it has shaped the legal landscape surrounding state officials' accountability and the protection of individual rights.
Ex Parte Young
Date: March 23, 1908
Citation: 209 U.S. 123
Issues: Eleventh Amendment; abstention doctrine
Significance: Although federal courts had not been allowed to intervene in pending state court proceedings, the Supreme Court held that in extraordinary circumstances, a federal court may issue an injunction ordering state officials not to enforce a state statute until its validity has been decided in court.
A 1907 Minnesota law reduced railroad rates and imposed severe day-to-day penalties for violations. In addition to challenging the reduced rates, the railroads asserted that the day-to-day fines were ruinous, which violated the due process requirements of the Fourteenth Amendment. Therefore, the railroads went to the federal district court to seek a temporary injunction to stop state officials from imposing the fine while the case was being adjudicated. A federal district court issued such an injunction to Edward Young, Minnesota’s attorney general. When Young was jailed for ignoring the order, he petitioned the Supreme Court for a writ of habeas corpus.
By an 8-1 vote, the Court upheld the injunction. Justice Rufus W. Peckham’s opinion for the majority justified the federal court’s action by creating a legal fiction. If the officer was enforcing an unconstitutional statute, the officer was not acting in his official capacity but was a private individual misusing the state’s authority for his own purposes. The lone dissenter, Justice John Marshall Harlan argued that the majority’s ruling would “practically obliterate the Eleventh Amendment.” Ironically, the Court subsequently determined, in Simpson v. Shepard (1913), that the 1907 law was constitutional, which meant that Young had not been acting illegally after all.
At the time, the Young decision was very unpopular. In 1910 Congress established special three-judge federal courts to handle suits for injunctions against state officers. The Johnson Act of 1934 prohibited most federal injunctions against state regulations of rates. After World War II, federal courts applied the Young doctrine when enjoining state officials from depriving persons of civil rights and civil liberties.