Atlantic Coast Line Railroad Co. v. Brotherhood of Locomotive Engineers

Supreme Court of the United States · 1970 · Federal Courts

Federal Courts28 U.S.C. § 2283Anti-Injunction Actstate court proceedingsprotect or effectuate judgmentsnecessary in aid of jurisdictionconcurrent jurisdictionfederalism

Facts

In 1967 the Brotherhood of Locomotive Engineers picketed ACL's Moncrief Yard in Jacksonville during a labor dispute involving the Florida East Coast Railway. ACL first sought a federal injunction, but the district court denied that request; ACL then obtained a Florida state court injunction against the picketing. After the Supreme Court decided Brotherhood of Railroad Trainmen v. Jacksonville Terminal Co. in 1969, the union moved in state court to dissolve the Moncrief Yard injunction, but the state court refused. The union then returned to federal court and obtained an injunction preventing ACL from availing itself of the state court injunction.

Issue

Whether the federal district court's injunction against use of the Florida state court injunction was permitted by 28 U.S.C. § 2283 either because it was necessary to protect or effectuate the district court's earlier 1967 order or because it was necessary in aid of the district court's jurisdiction.

Rule

Under 28 U.S.C. § 2283, a federal court may not enjoin state court proceedings unless the injunction falls within one of the statute's specifically defined exceptions. The Act is a binding prohibition, not a mere principle of comity, and its exceptions must not be enlarged by loose construction. The "protect or effectuate its judgments" exception applies only when a prior federal judgment actually decided the matter the state proceeding threatens to undermine, and the "necessary in aid of its jurisdiction" exception requires more than mere interference with a federal right or overlapping jurisdiction.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Phoenix, Desert Mesa Transit sued a drivers' guild in federal district court seeking to stop a strike. The federal judge denied relief, and Desert Mesa then obtained a state-court injunction barring the strike. The guild returned to federal court and asked for an order forbidding Desert Mesa from enforcing the state injunction, arguing that federal labor policy clearly protects the strike.

Should the federal court issue the requested order?

Explanation. The governing rule is that 28 U.S.C. § 2283 is an absolute prohibition against federal injunctions staying state-court proceedings unless one of the statute's expressly defined exceptions applies. The Court rejected the idea that the Act is merely a principle of comity or that lower federal courts may create additional exceptions based on perceived federal supremacy or equity. An order directed to a party rather than the state judge still counts if it bars use of the state-court injunction.