Salazar v. Buono - 559 U.S. 700, 130 S. Ct. 1803 (2010)

Rule:

An injunction is an exercise of a court's equitable authority, to be ordered only after taking into account all of the circumstances that bear on the need for prospective relief. Equitable relief is not granted as a matter of course and a court should be particularly cautious when contemplating relief that implicates public interests. In exercising their sound discretion, courts of equity should pay particular regard for the public consequences in employing the extraordinary remedy of injunction. Where an important public interest would be prejudiced, the reasons for denying an injunction may be compelling. Because injunctive relief is drafted in light of what the court believes will be the future course of events, a court must never ignore significant changes in the law or circumstances underlying an injunction lest the decree be turned into an instrument of wrong.

Facts:

In 1934, members of the Veterans of Foreign Wars (VFW) mounted the Latin cross on Sunrise Rock within the Preserve as a memorial to soldiers who died in World War I. The citizen, a retired Park Service employee who made regular visits to the Preserve, alleged a violation of the Establishment Clause. The district court did not consider whether the land transfer itself was an independent violation of the Establishment Clause; nevertheless, it concluded that the transfer was an attempt by the Government to keep the cross atop Sunrise Rock contrary to an earlier injunction and so was invalid.

Issue:

Did the district court err in enjoining Federal Government from implementing federal statute purporting to transfer Latin cross--and public land on which it had been erected--in exchange for private land? 

Answer:

Yes.

Conclusion:

The judgment was reversed and the case was remanded for further proceedings. According to the court, the district court did not engage in the appropriate inquiry. The land-transfer statute was a substantial change in circumstances bearing on the propriety of the requested relief. By dismissing Congress's motives as illicit, the district court took insufficient account of the context in which the statute was enacted and the reasons for its passage. On remand, if the citizen continued to challenge implementation of the statute, the district court was instructed to conduct a proper inquiry as described in the Court's opinion.