Law School Case Brief
Mitchum v. Foster - 407 U.S. 225, 92 S. Ct. 2151 (1972)
42 U.S.C.S. § 1983 is a product of a vast transformation from the concepts of federalism that had prevailed in the late 18th century when the anti-injunction statute was enacted. The very purpose of § 1983 is to interpose the federal courts between the states and the people, as guardians of the people's federal rights: to protect the people from unconstitutional action under color of state law, whether that action be executive, legislative, or judicial. In carrying out that purpose, Congress plainly authorized the federal courts to issue injunctions in § 1983 actions, by expressly authorizing a "suit in equity" as one of the means of redress. Federal injunctive relief against a state court proceeding can in some circumstances be essential to prevent great, immediate, and irreparable loss of a person's constitutional rights. For these reasons, under the criteria established in previous decisions construing the anti-injunction statute, § 1983 is an Act of Congress that falls within the "expressly authorized" exception of that law.
The prosecuting attorney of Bay County, Florida, brought a proceeding in a Florida court to close down the appellant's bookstore as a public nuisance under the claimed authority of Florida law. The state court entered a preliminary order prohibiting continued operation of the bookstore. After further inconclusive proceedings in the state courts, the appellant filed a complaint in the United States District Court for the Northern District of Florida, alleging that the actions of the state judicial and law enforcement officials were depriving him of rights protected by the First and Fourteenth Amendments. Relying upon 42 U. S. C. § 1983, he asked for injunctive and declaratory relief against the state court proceedings, on the ground that Florida laws were being unconstitutionally applied by the state court so as to cause him great and irreparable harm. The district court refused to enjoin the state court proceeding because the relief sought did not come under any of the exceptions set forth in 28 U.S.C.S. § 2283.
Did the district court err in its decision to deny the injunctive relief prayed for by the appellant?
The Court reversed the district court's order denying injunctive relief and remanded the case for further proceedings because the statute under which the bookstore owner sought relief was an authorized exception to the Anti-Injunction Act. The Court held that federal injunctive relief was appropriate only where the irreparable injury was both great and immediate, the state law was flagrantly unconstitutional, or there was a showing of bad faith that would call for equitable relief. The Court added that to qualify under one of those expressly authorized exceptions, the federal law did not have to expressly reference § 2283. The test was whether an act of Congress, clearly creating a federal right enforceable in a federal court of equity, could be given its intended scope only by the stay of a state proceeding. The Court held that 42 U.S.C.S. § 1983 fell within the exception.
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