Ex parte Young
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Ex Parte Young, 209 U.S. 123 (1908), was a United States Supreme Court case that allowed suits against officials acting on behalf of states of the union to proceed despite the State's sovereign immunity, when the State acted unconstitutionally. Court citation is a standard system used in common law countries such as the United States, United Kingdom, Canada, and Australia to uniquely identify the location of past court cases in special series of books called reporters. ... 1908 is a leap year starting on Wednesday (link will take you to calendar). ... The Supreme Court Building, Washington, D.C. The Supreme Court Building, Washington, D.C., (large image) The Supreme Court of the United States, located in Washington, D.C., is the highest court (see supreme court) in the United States; that is, it has ultimate judicial authority within the United States... Sovereign immunity or crown immunity is a type of immunity that, in common law jurisdictions traces its origins from early English law. ...

Facts

The state of Minnesota passed laws limiting what railroads could charge in that state, and establishing severe penalties, including fines and jail for violators. Some railroad company shareholders filed a lawsuit asserting that the laws were unconstitutional as violating Fourteenth Amendment due process, as well as the Commerce Clause. The shareholders sued the railroads to prevent them from complying with the law, and also sued Edward T. Young, then the Attorney General of Minnesota, to prevent him from enforcing the law. State nickname: North Star State Other U.S. States Capital Saint Paul Largest city Minneapolis Governor Tim Pawlenty (R) Official languages None Area 225,365 km² (12th)  - Land 206,375 km²  - Water 18,990 km² (8. ... This is the top-level page of WikiProject trains Rail tracks Rail transport refers to the land transport of passengers and goods along railways or railroads. ... A shareholder or stockholder is an individual or company (including a corporation), that legally owns one or more shares of stock in a joint stock company. ... Amendment XIV (the Fourteenth Amendment) of the United States Constitution is one of the post-Civil War amendments and includes the due process and equal protection clauses (Section 1). ... Article I, Section 8, Clause 3 of the United States Constitution, known as the Commerce Clause, empowers the United States Congress To regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes. ... In most common law jurisdictions, the Attorney General is the main legal adviser to the government, and in some jurisdictions may in addition have executive responsibility for law enforcement or responsibility for public prosecutions. ...

Young argued that the Eleventh Amendment, which prohibits states from being sued by their citizens, meant that the court did not have jurisdiction to hear the case. The federal court nevertheless issued an injunction against Young enforcing the law. The following day, Young filed a proceeding in the state court to force the railroads to comply with the statute. The federal judge ordered Young to explain his actions, and Young reiterated his Eleventh Amendment claim, whereupon the judge held Young in contempt of court. Young was threatened with incarceration, but was permitted to file a writ of habeas corpus in the U.S. Supreme Court. Amendment XI (the Eleventh Amendment) of the United States Constitution was passed by the US Congress on March 4, 1794 and was ratified on February 7, 1795. ... In law, jurisdiction refers to the aspect of a any unique legal authority as being localized within boundaries. ... An injunction is an equitable remedy in the form of a court order that either prohibits or compels (enjoins or restrains) a party from continuing a particular activity. ... Contempt of court is the failure to obey a lawful order of a court, disrespect for the judge, disruption of the proceedings through poor behavior, or publication of material deemed likely to jeopardize a fair trial. ... A prison is a place in which people are confined and deprived of a range of liberties. ... In common law jurisdictions, habeas corpus, or more precisely habeas corpus ad subjiciendum, is a prerogative writ which requires the addressee to produce in court a person in its custody and justify his or her imprisonment. ...

Issue

The Supreme Court faced two issues here. The first involved three questions as to the constitutionality of the Minnesota statutes:

• 1. Did the statutes violate Fourteenth Amendment due process by setting too low a cap on the rates that railroads could charge?
• 2. Did the statutes violate Fourteenth Amendment due process by establishing punishments so harsh that no one would challenge the laws, for fear of the consequences of losing such a challenge?
• 3. Did the statutes violate the Commerce Clause by interfering with commerce between the states?

The second issue exposed the tension between the Eleventh Amendment and the Fourteenth Amendment. The Eleventh Amendment had recently been held in Hans v. Louisiana, 134 U.S. 1 (1890), to prohibit federal courts from hearing suits by citizens against their own states. Conversely, the Fourteenth Amendment prohibits the states from violating the Constitutional rights of their citizens. Could a federal court entertain a lawsuit seeking to enjoin a state official from carrying out state laws that were purportedly in violation of the Fourteenth Amendment? Holding --- Court membership Case opinions Laws applied --- Hans v. ... Court citation is a standard system used in common law countries such as the United States, United Kingdom, Canada, and Australia to uniquely identify the location of past court cases in special series of books called reporters. ... 1890 was a common year starting on Wednesday (see link for calendar). ... The United States federal courts are the system of courts organized under the Constitution and laws of the federal government of the United States. ...

Result

The Court, in an opinion written by Justice Peckham quickly found that the Minnesota laws with respect to the railroad rates were unconstitutional, and moved on to the issue of whether the state official could be enjoined from prosecuting violations of such laws.

Failure to enjoin the unconstitutional statute would either require the person subject to a potential violation to either pay the increased rate or face the threat of prosecution. Therefore, the Court determined that it would be unfair to require challengers of a law to wait until they faced a harsh sanction before they could bring any kind of action questioning the validity of that law. The Court also noted that, although a number of cases had held that the state itself could not be sued, those cases did not prohibit enjoining a state official, as an individual, from carrying out some task on behalf of the state.

Young contended that he was merely acting for the state of Minnesota when he sought to enforce its laws. The Court disagreed, holding that when a state official does something that is unconstitutional, the official can not possibly be doing it in the name of the state, because the Supremacy Clause of the Constitution means that the Constitution over-rides all the laws of the states, invalidating any contrary laws. Therefore, when a state official attempts to enforce an unconsitutional law, that individual is stripped of his official character. He becomes merely another citizen who can constitutionally be brought before a court by a party seeking injunctive relief. The Supremacy Clause appears in Article VI of the United States Constitution. ...

The Court, in laying out this doctrine, created two legal fictions: In the common law, legal fictions, are suppositions of fact taken to be true by the courts of law, but which are not necessarily true. ...

• 1. That such a suit is not against the state, but merely against the individual officer who can not be acting on behalf of the state when he enforces a law that is unconstitutional; and
• 2. An individual can be a state actor for 14th Amendment purposes (which only prohibits unconstitutional act by the state, and those who represent it) while remaining a private person for 11th Amendment purposes.

The Court also rejected the contention raised by Young that an injunction was inappropriate because the railroads could get an adequate remedy by testing the statute in the courts. The Court noted that the railroads could never recover the costs of obeying the law while waiting for it to be adjudicated unconstitutional.

Based on these findings, the Court held that suits may be brought to enjoin state officials from enforcing unconstitutional laws in the United States District Courts, which have the power to enjoin those officials from enforcing such laws.

Dissent

Justice John Marshall Harlan angrily dissented, writing that the only reason that the suit was brought against Young was because he represented the state, and that the result of the suit would be to "tie the hands of the state". This was therefore no different from a suit against the state itself, prohibited by the Eleventh Amendment. John Marshall Harlan John Marshall Harlan (June 1, 1833 – October 14, 1911) was an American Supreme Court associate justice. ...

Harlan observed that the state can never act except through its officers, and this decision would deprive the state of the representation of its officers in court. He therefore condemned the decision as a "radical change in our government system" that "would place the states of the Union in a condition of inferiority never dreamed of when the Constitution was adopted or when the Eleventh Amendment was made a part of the supreme law of the land."

Harlan also contended that Constitutional rights can be enforced by suits in the state courts, instead of the federal courts. If the state's trial courts did not enforce the Constitution, they could be appealed up to the state supreme court, which could then be appealed to the U.S. Supreme Court.

Later Developments

As a consequence of Ex Parte Young, Congress passed two important statutes:

• § 28 U.S.C. 2201, which gives federal courts the power "to declare the rights and other legal relations of any interested party" and provides that "Any such declaration shall have the force and effect of a final judgment"; and
• § 28 U.S.C. 2202, which says that "Further necessary or proper relief based on a declaratory judgment or decree may be granted, after reasonable notice and hearing, against any adverse party."

The effect of the first statute is to permit the federal courts to declare the rights of a party suing a state official (or any other party, but they were created with state officials in mind) without issuing an injunction against the official. This was thought to be more respectful of the states. However, if the court declares a statute to be unconstitutional, and the state official still prosecutes someone for violating the statute, then the second statute kicks in, permitting the federal court to take action such as issuing an injunction and holding an official who violates that injunction in contempt.

External link

• 209 U.S. 123 (Text of the opinion on Findlaw.com)