Home Tel. & Tel. Co. v. Los Angeles, 227 U.S. 278 (1913)
Actions based on violations by state officials of the Fourteenth Amendment can proceed in federal court, despite the absence of a determination by a state court on whether their actions also violated the state constitution.
An ordinance in the city of Los Angeles set the rates that Home Telephone & Telegraph Co. could charge to its customers. It sued the city and several city officials, seeking an injunction against the enforcement of the ordinance. It argued that the rates set by the city were so unreasonably low that enforcing them would result in a taking of property without due process. The City argued that the federal court should not hear the case until a state court had determined whether the ordinance was valid under the California Constitution. The lower court agreed and dismissed the case on jurisdictional grounds.Opinions
- Edward Douglass White (Author)
- Joseph McKenna
- Oliver Wendell Holmes, Jr.
- William Rufus Day
- Horace Harmon Lurton
- Charles Evans Hughes
- Willis Van Devanter
- Joseph Rucker Lamar
- Mahlon Pitney
Previous decisions had required state courts to evaluate the validity of provisions under state constitutions before federal courts could determine whether they were constitutional under the Fourteenth Amendment. These cases were poorly decided, since the Fourteenth Amendment is intended to serve a prophylactic function. Taking this interpretation would close off a means of seeking recourse for the improper actions of state officials. A threat of substantial harm exists in this case, so the federal court should be able to hear the case without delay.Case Commentary
This is an example of federal question jurisdiction, which is an independent basis of authority for federal courts. It can be based on either the Constitution or a federal statute.
U.S. Supreme CourtHome Tel. & Tel. Co. v. Los Angeles, 227 U.S. 278 (1913)
Home Telephone and Telegraph Company v. Los Angeles
Submitted October 28, 1912
Decided February 24, 1913
227 U.S. 278
One whose rights protected by a provision of the federal Constitution which is identical with a provision of the state constitution are invaded by state officers claiming to act under a state statute is not debarred from seeking relief in the federal court under the federal Constitution until after the state court has declared that the acts were authorized by the statute.
The provisions of the Fourteenth Amendment are generic in terms, and are addressed not only to the states but to every person, whether natural or judicial, who is the repository of state power.
The reach of the Fourteenth Amendment is coextensive with any exercise by a power, in whatever form exerted.
Under the Fourteenth Amendment, the federal judicial power can redress the wrong done by a state officer misusing the authority of the state with which he is clothed; under such circumstances, inquiry whether the state has authorized the wrong is irrelevant. Ex Parte Young, 209 U. S. 123, followed. Barney v. New York, 193 U. S. 430, distinguished.
Acts done under the authority of a municipal ordinance passed in virtue of power conferred by the state are embraced by the Fourteenth Amendment.
The power which exists to enforce the guarantees of the Fourteenth Amendment is typified by the immediate and efficient federal right to enforce the contract clause of the Constitution as against those violating or attempting to violate its provision.
The facts, which involve the jurisdiction of the District Court of a suit arising under the due process clause of the Fourteenth Amendment and the validity of an ordinance of Los Angeles, California, establishing telephone rates, are stated in the opinion.