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In re Debs - 158 U.S. 564, 15 S. Ct. 900 (1895)

Rule:

The United States, given by the U.S. Constitution power to regulate interstate commerce by express statute, assumes jurisdiction over interstate commerce when carried upon railroads. The United States is charged with the duty of keeping those highways of interstate commerce free from obstruction, for it has always been recognized as one of the powers and duties of a government to remove obstructions from the highways under its control.

Facts:

The union officers claimed that the United States lacked standing to seek an injunction against them to prevent them from disrupting railroad operation and that the federal courts lacked jurisdiction to order an injunction and enforce it by contempt. The United States claimed that pursuant to its obligation to regulate interstate commerce it had an interest in the continued operation of the railroads because the mail was carried on the railroads, and that the federal courts had jurisdiction to issue an injunction against the union officers and enforce the order by contempt. The union officers, who ignored the court orders and were held in contempt by the circuit court, sought a writ of habeas corpus from the court.

Issue:

  1. Did the relations of the general government to interstate commerce and the transportation of the mails authorize a direct interference to prevent a forcible obstruction thereof?
  2. Did federal courts have jurisdiction to issue an injunction against the union officers and enforce the order by contempt? 

Answer:

1) Yes. 2) Yes.

Conclusion:

The court denied the union officers' application for a writ of habeas corpus, and held that U.S. Const. art. I, § 8 gave the United States the power to regulate interstate commerce, which included the mail in which the United States had a property interest, and that the United States had standing to request an injunction against the union officers. Moreover, the federal courts had jurisdiction as courts of equity to issue the injunction. Issuing the injunction was meaningless unless the order could be enforced by contempt, and the United States would only have the armed forces available to enforce its regulation of interstate commerce.

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