Ex parte Young

Supreme Court of the United States · 1908 · Federal Courts

209 U.S. 123 (1908)

Updated August 1, 2026

Federal Courtssuits against state officersEleventh AmendmentFourteenth Amendmentstate officersinjunctionunconstitutional statutefederal question

Facts

Stockholders of the Northern Pacific Railway Company filed suit in federal circuit court challenging Minnesota statutes and commission orders fixing freight and passenger rates. They alleged the rates were confiscatory and that the statutes imposed enormous fines and imprisonment that effectively prevented judicial review of the statutes' validity. The circuit court issued a temporary injunction barring enforcement of the rate laws, including by the Minnesota Attorney General. After the Attorney General nevertheless began state mandamus proceedings to enforce the commodity act, the circuit court held him in contempt, and he sought relief in the Supreme Court.

Issue

Whether the federal circuit court had jurisdiction to hear the constitutional challenge and to enjoin the Minnesota Attorney General from enforcing the state rate statutes, or whether the suit was in effect a prohibited suit against the State under the Eleventh Amendment. Also, whether the penalty provisions of the rate acts were unconstitutional because they effectively denied access to judicial review.

Rule

A suit to enjoin a state officer from enforcing an unconstitutional state enactment is not a suit against the State within the meaning of the Eleventh Amendment when the officer has some connection with enforcement of the act. When a state officer attempts to enforce an unconstitutional enactment, he is stripped of official or representative character and may be restrained in equity. Further, a statute is unconstitutional on its face when its fines and imprisonment are so severe that they effectively preclude resort to the courts to test the statute's validity.

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

A nonprofit hospital in Columbus, Ohio challenges a new Ohio statute capping reimbursement rates it may charge state-regulated plans. The hospital sues the Ohio attorney general in federal court for an injunction, alleging the statute violates the Fourteenth Amendment, and Ohio law generally authorizes the attorney general to institute proceedings to enforce state laws. The attorney general has publicly announced he will file enforcement actions next week.

Is the federal suit barred as a suit against the State?

Explanation. The majority held that a suit against a state officer is not treated as a suit against the State when the officer has some connection with enforcement of the challenged enactment. That connection need not arise from the statute being challenged; general enforcement authority is enough if it actually exists. Because the attorney general here has authority under state law to enforce state statutes and is threatening enforcement, the federal action is not barred by the Eleventh Amendment.