Walker v. City of Birmingham

Brief Fact Summary.

Plaintiffs willfully disobey an injunction enjoining them from protesting. They are then held in contempt of court and appeal this decision.

Synopsis of Rule of Law.

An injunction issuing out of a court of general jurisdiction with equity powers must be followed, however erroneous the action of the court may be. The proper venue to challenge the injunction is through the courts.

Facts.

Defendant City of Birmingham filed for an injunction to stop 139 people from protesting, claiming it would endanger the safety and welfare of citizens. The court granted a preliminary injunction enjoining the named persons from engaging in mass processions. Eight people, including Plaintiff Walker, still marched. Plaintiffs held a press conference prior to marching stating that they would not follow the injunction because they believed it violated their First and Fourteenth Amendment rights. After the march city officials attempted to keep the court from holding Plaintiffs in contempt of court, but the court refused to waive the infraction because Plaintiffs did not attempt to dissolve the injunction prior to violating it. The court found Plaintiffs in contempt and sentenced them to five days in jail and a $50 fine. Plaintiffs appealed, but the Supreme Court of Alabama affirmed. The United States Supreme Court granted certiorari.

Issue.

Must an injunction out of a court of general jurisdiction with equity powers be obeyed however erroneous the action of the court?

Held.

Yes, an injunction out of a court with general jurisdiction with equity powers must be obeyed however erroneous the action of the court, and the proper venue to challenge the injunction is through the courts. The holding of the lower courts is affirmed.

Dissent.

Justice Chief Justice Warren with Justices Brennan and Fortas dissenting

The Alabama statute is unconstitutional, but the court is saying that Plaintiffs may be convicted under it since it was incorporated into an  injunction. The injunction was not issued to allow the court time to resolve a dispute, because there wasn’t one. The injunction only added criminal contempt charges to a law that already made it unlawful for Plaintiffs to protest.

Justice Justice Douglas with The Chief Justice and Justice Brennan and Fortas dissenting

A state cannot keep people from petitioning for a redress of grievances. To do so is unconstitutional. Here, the court allows this unconstitutional behavior when it does not have the authority to do so.

Discussion.

1. It is grounded in precedent and history that trial courts have the power to issue injunctions and hold parties who violate the order in contempt.
2. The proper method to dispute the injunctions is by petitioning the court, not by disobeying the order.
3. While the injunctions probably would not have withstood constitutional scrutiny, Plaintiffs were not entitled to disregard the order without addressing the issue with the court.
4. Case law and an Alabama statute notified Plaintiffs that they could not ignore the court before violating the injunctions.
5. Holding of the lower court is affirmed.