In making an officer of the state a party defendant in a suit to enjoin the enforcement of an act alleged to be unconstitutional it is plain that such officer must have some connection with the enforcement of the act, or else it is merely making him a party as a representative of the state, and thereby attempting to make the state a party. It has not, however, been held that it was necessary that such duty should be declared in the same act which is to be enforced. The fact that the state officer by virtue of his office has some connection with the enforcement of the act is the important and material fact, and whether it arises out of the general law, or is specially created by the act itself, is not material so long as it exists.
Petitioner, Edward T. Young, a state's attorney general, sought a writ of habeas corpus and a writ of certiorari after he was punished for contempt in the Circuit Court of the United States for the District of Minnesota for violation of that court's injunction, which prohibited him from enforcing unconstitutional railroad acts in a suit brought by complainants stockholders against defendant railroad. Young contended that the lower court did not have jurisdiction to enjoin him.
Did the Circuit Court of the United States for the District of Minnesota have jurisdiction to enjoin Edward T. Young from enforcing unconstitutional railroad acts?
The Court held that the circuit court had jurisdiction because the case involved the decision of federal questions arising under the Constitution of the United States. The Court found that the Acts were unconstitutional because their provisions imposed stiff penalties on railroad companies that were unsuccessful in trying to test the validity of the laws. The Eleventh Amendment was not violated by allowing the lower court to enjoin an officer of the state who was enforcing a law that was in violation of the federal constitution. Such action did not constitute an action against the state. According to the Court, Young had a duty to enforce the laws of the state, and the injunction was against him, not the state.