International Longshoremen’s Local 37 v. Boyd

Brief Fact Summary.

International Longshoremen’s Local 37 (Plaintiff) sought a judicial declaration that its alien members who traveled outside of the United States for work would not be treated as entering the country for the first time upon their return.

Synopsis of Rule of Law.

A court should not attempt to determine the scope and constitutionality of legislation before the statue has actually imposed an adverse effect in a concrete case.

Facts.

Every summer members of the Plaintiff organization, including aliens domiciled in the United States would travel to canneries in Alaska for work. Plaintiff sued to enjoin Boyd (Defendant), an immigration official, from applying immigration laws to treat the alien members as though they were entering the United States for the first time. Plaintiff also sought a declaration that this potential interpretation of the law was unconstitutional. The district court reached the merits, but dismissed. Plaintiff appealed and Defendant argued that the action should have been dismissed for lack of jurisdiction, as no case or controversy existed.

Issue.

Should a court determine the constitutionality of a statute before the statute has been applied in an actual case? 

Held.

(Frankfurter, J.) No. A court should not attempt to determine the scope and constitutionality of legislation before the statue has actually imposed an adverse effect in a concrete case. Plaintiff’s request for declaratory relief is based upon hypothetical situations that may or may not take place. The suit is dismissed for lack of a case or controversy.

Dissent.

(Black, J.) The situation described by Plaintiff in this case is not hypothetical nor remote. The statute has already been applied in the manner feared by Plaintiff and will result in irreparable injury to those against whom it is enforced in the future. The statutory interpretation Plaintiff argues against may well be constitutional, but the Plaintiff’s case should be decided on the merits.

Discussion.

Although the jurisdiction of courts is limited to cases and controversies, the use of declaratory judgments provides some flexibility in cases where imminent and irreparable harm are threatened. Where parties would incur significant damages unnecessarily, courts may step in with declaratory relief.