United Public Workers v. Mitchell

Brief Fact Summary.

Plaintiffs sued to enjoin the Civil Service Commission from enforcing the Hatch Act.

Synopsis of Rule of Law.

Pursuant to Article III of the Constitution, federal courts may not render advisory opinions on constitutional issues in the absence of an actual interference with the parties’ interests.

Facts.

Poole and other federal civil service employees (Plaintiffs) seek a declaratory judgment that the Hatch Act violates the First Amendment by prohibiting them from participating in political campaigns. Poole violated the Hatch Act by engaging in political activity, and there is a proposed order for his removal from his position. The other plaintiffs have not yet violated the Hatch Act, but claim that they wish to do so by serving as party officials or writing articles in support of candidates, for example. The United States District court for the District of Columbia dismissed Plaintiffs’ complaint and granted summary judgment for Defendants.

Issue.

Whether the Court may render a declaratory judgment on the constitutionality of a law, based on the claim that possible future actions of the parties will cause them to violate the law.

Held.

No. The district court’s ruling is affirmed. Pursuant to Article III of the Constitution, federal courts may not render advisory opinions on constitutional issues in the absence of an actual interference with the parties’ interests.

Dissent.

Douglas, J. : The threat to the plaintiffs is actual, not hypothetical. If they undertake their proposed actions, they will be removed from their positions. Requiring a violation and discharge from employment would cause lower income employees to suffer irreparable injury.

Discussion.

The Court may not rule on the constitutionality of the Hatch Act based on the plaintiffs’ claim that their possible future actions will cause them to violate the Act. This Court, and federal courts established under Article III, may decide the constitutionality of acts of Congress only when necessary to protect litigants’ interests from actual interference, not hypothetical threats. A general threat of possible interference with a person’s civil rights if he takes a certain action is not sufficient to create a justiciable case or controversy. To permit otherwise would be an abuse of judicial power, and would intrude on the powers granted to the executive and legislative branches. Here, plaintiffs’ claim that their possible future actions will cause them to violate the Hatch Act is insufficient to create a justiciable case or controversy. However, Poole has admitted to violating the Hatch Act by engaging in political activity, making his removal from office mandatory under the Act.