Law School Case Brief
Bowles v. Willingham - 321 U.S. 503, 64 S. Ct. 641 (1944)
The provisions of the Emergency Price Control Act (56 Stat at L 23, 765) giving the Administrator authority to seek injunctive relief in the appropriate court against the receipt of rent in violation of any regulation issued under the Act, and confining relief against orders of the Administrator to the judicial review granted to the Emergency Court of Appeals, constitute legislative exceptions to the provision of 265 of the Judicial Code (28 USC 379) forbidding Federal courts to issue injunctions against state proceedings, and, therefore, a Federal District Court has jurisdiction to entertain a suit to enjoin the prosecution of a suit brought in a state court to restrain the issuance of certain rent orders.
Mrs. Willingham of Macon, Georgia owned several rental units and was notified by Bowles, Administrator of the Office of Price Administration, of the fixing of maximum rent, which caused Mrs. Willingham to file suit in state court restraining Bowles from taking any further action. The state court issued a temporary injunction and show cause order, and Bowles brought an action in federal district court, which was dismissed on constitutional grounds.
Does a district court have jurisdiction to entertain a suit to enjoin the prosecution of a suit brought in a state court to restrain the issuance of certain rent orders?
The United States Supreme Court reversed the order of the district court that dismissed Bowles’ suit to restrain Mrs. Willingham from further prosecution in state court and from violation of the Emergency Price Control Act of 1942 (Act). On review, the Court found that the Act specifically provided for relief and enforcement in district court and that where Congress had provided for judicial review after the regulations or orders had been made effective it had done all that due process under the war emergency required. The Court noted that there was not unbridled administrative discretion because the location of rent control and criteria to guide the administrator were not vague.
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