Douglas v. City of Jeannette

Supreme Court of the United States · 1943 · Federal Courts

Federal Courtsequityinjunctionstate criminal prosecutionsCivil Rights Act42 U.S.C. § 1983 precursorfederal jurisdictionirreparable injury

Facts

Jehovah's Witnesses sued the City of Jeannette and its Mayor to stop threatened state prosecutions under a city ordinance requiring a license and tax for soliciting orders for merchandise. They alleged that, as applied to their house-to-house distribution of religious books and pamphlets, the ordinance abridged freedoms of speech, press, and religion, and that respondents had already arrested and prosecuted them and threatened to continue doing so. The complaint invoked the Constitution and the Civil Rights Act of 1871. In the related Murdock decision issued the same day, the ordinance as applied was held unconstitutional.

Issue

Did the federal district court have statutory jurisdiction to hear this suit under the Civil Rights Act without any jurisdictional amount, and if so, could a federal court of equity enjoin threatened state criminal prosecutions under the ordinance? More specifically, had petitioners shown the sort of irreparable injury necessary for equitable intervention?

Rule

A federal district court has jurisdiction under the Civil Rights Act and the federal jurisdiction statute to hear a suit alleging that state officials, acting under color of a state ordinance, are depriving persons of First Amendment rights made applicable to the states by the Fourteenth Amendment, without any allegation or proof of a jurisdictional amount. But a federal court of equity should not ordinarily restrain threatened state criminal prosecutions; such relief is warranted only in exceptional cases showing a clear and imminent danger of irreparable injury that is both great and immediate, and not merely the ordinary burdens of a good-faith criminal prosecution.

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

In Toledo, Ohio, Lena Ortiz alleges that city inspectors and police are threatening to charge her under a municipal leafleting ordinance whenever she distributes political pamphlets on sidewalks. She files in federal district court against the city manager under the Civil Rights Act, seeks only injunctive relief, and does not allege any dollar amount in controversy.

Which is the strongest argument that the federal district court has subject-matter jurisdiction?

Explanation. The majority distinguished jurisdiction from entitlement to equitable relief. It held that district courts have jurisdiction over suits under the Civil Rights Act alleging deprivation of constitutional rights under color of a state or municipal ordinance, without allegation or proof of a jurisdictional amount. Diversity is unnecessary. Whether an injunction should issue is a separate equity question.