Atl. C. L. R. Co. v. Bhd. of Locomotive Eng'rs

398 U.S. 281, 90 S. Ct. 1739 (1970)

 

RULE:

The Anti-Injunction Act is an absolute prohibition against enjoining state court proceedings, unless the injunction falls within one of three specifically defined exceptions. This is not a statute conveying a broad general policy for appropriate ad hoc application. Any injunction against state court proceedings otherwise proper under general equitable principles must be based on one of the specific statutory exceptions to 28 U.S.C.S. § 2283 if it is to be upheld. Moreover, since the statutory prohibition against such injunctions in part rests on the fundamental constitutional independence of the states and their courts, the exceptions should not be enlarged by loose statutory construction. Proceedings in state courts should normally be allowed to continue unimpaired by intervention of the lower federal courts, with relief from error, if any, through the state appellate courts and ultimately the Supreme Court of the United States.

FACTS:

After petitioner Atlantic Coast Line Railroad Company (ACL) had sought and been denied, in a Federal District Court in Florida, an injunction against respondent Brotherhood of Locomotive Engineers’ (BLE) picketing of a switching yard, ACL sought and obtained such an injunction in a Florida state court. About two years later, BLE filed a motion in the state court seeking to dissolve the injunction on the ground that it was improper under the United States Supreme Court decision in Railroad Trainmen v. Jacksonville Terminal Co., 394 U.S. 369 (1969), which enunciated that unions had a federally protected right to picket the terminal without interference by state court injunctions. The state court, holding that the aforementioned Supreme Court decision was distinguishable, refused to dissolve the injunction. BLE then sought and obtained an injunction in the Federal District Court against the enforcement of the state court injunction, and the United States Court of Appeals for the Fifth Circuit affirmed. The Supreme Court of the United States granted ACL's petition for certiorari to consider the validity of the federal court's injunction against the state court.

ISSUE:

In a case involving the prohibitions of the Anti-Injunction Act, did the Federal District Court err in its decision to grant an injunction in favor of BLE, a union that had been enjoined from picketing?

ANSWER:

Yes.

CONCLUSION:

The Supreme Court of the United States held that the federal injunction against the state court was improper because the federal injunction was not invoked under 28 U.S.C.S. § 2283 of the Anti-Injunction Act either to effectuate the district court's earlier denial of an injunction against ACL to prohibit BLE from picketing, or as necessary in aid of the district court's jurisdiction. The Court ruled that the district court's earlier order did not determine BLE’s right to picket free from state interference; thus, BLE was improperly attempting to seek review of a state decision in the district court and it could not be justified as necessary to effectuate that order. According to the Court, the district court was not free to enjoin the state court on the theory that such action was necessary in aid of jurisdiction because it did not have inherent power to ignore § 2283 and to enjoin the state court proceedings merely because those proceedings interfered with federal rights. The Court vacated the judgment of the district court and, because the district court had not yet proceeded to a final judgment in the case, the cause was remanded to it for further proceedings.

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