Brief Fact Summary.
Stockholders of the railroads in Minnesota challenged the state law that provided substantial punishments for any railroad which violated the provisions of the law and brought suits against the railroad company, members of the railroad commission, and the attorney general of the state, Edward Young.
Synopsis of Rule of Law.
Individuals who, as officers of the state, are representing the state in regard to the enforcement of the laws of the state and who threaten to enforce against parties affected by an unconstitutional act, are violating the federal Constitution and may be enjoined by the federal court from such action.
The Fourth Circuit has explained that this exception is directed at officers of the state who are clothed with some duty in regard to the enforcement of the laws of the state, and who threaten and are about to commence proceedings to enforce against parties affected by an unconstitutional act.View Full Point of Law
The Minnesota state legislature created a railroad commission which fixed the rates for various railroad companies in the state. The statute provided substantial punishments for any railroad which violated the provisions of the law. The railroad company did not comply with the provisions of the act with respect to the adoption and rates. Before the act was to take effect, stockholders of the railroads brought suits. The order restrained Young from taking any steps against the railroads to impose the penalties. Young argued that the court had no jurisdiction to enjoin him from performing his discretionary official duties, claiming that he was merely enforce a law of the state of Minnesota and thus the court order was in conflict with the 11th Amendment of the Constitution.
Does the act of the state official, if enforcing a state statute that was found to be unconstitutional, thereby violate the Constitution?
Yes, the rate statutes are found to be unconstitutional, and the use of the name of the state to enforce an unconstitutional act to the injury of complainants is a proceeding without the authority of the state in its sovereign or governmental capacity. It is an illegal act upon the part of a state official in attempting to enforce a legislative enactment which is void because it’s unconstitutional.
Within the true meaning of the 11th Amendment, the suit brought in the federal court was one against the state and therefore it was a suit to which the judicial power of the United States did not and could not extend to a state official. If it were otherwise, it would result in a radical change in our governmental system. It would enable the subordinate federal courts to supervise and control the official action of the states as if they were dependencies. It would place the states in a condition of inferiority never dreamed of when the Constitution was adopted.
If the act that the state official such as a state attorney general here seeks to enforce be a violation of the Constitution, the officer, in proceeding under such enactment, comes into conflict with the superior authority of the Constitution and he is stripped of his official or representative character and is subjected to the consequences in his individual conduct. The state has no power to impart from any immunity from responsibility to the supreme authority of the United States. It would be an injury to complainants to harass it with a multiple suits or litigation in an effort to enforce penalties under an unconstitutional enactment. Because the rate statutes of Minnesota has been found unlawful, the attorney general, who seeks to enforce the penalties under the statute, would violate the Constitution.