American Federation of Labor v. Watson
Annotate this Case
327 U.S. 582 (1946)
U.S. Supreme Court
American Federation of Labor v. Watson, 327 U.S. 582 (1946)
American Federation of Labor v. Watson
Argued February 8, 1946
Decided March 25, 1946
327 U.S. 582
1. Section 24(8) of the Judicial Code, granting federal district courts jurisdiction of all "suits and proceedings arising under any law regulating commerce," applies to a suit seeking to protect rights asserted under the National Labor Relations Act. P. 327 U. S. 589.
2. Section 266 of the Judicial Code, providing that only a three-judge court may issue an interlocutory injunction suspending or restraining "the enforcement, operation, or execution of any statute of a State," applies to a suit in a federal court to enjoin the enforcement of a provision of a state constitution. P. 327 U. S. 591.
(a) The policy underlying § 266 admits no distinction between state action to enforce a constitutional provision and state action to enforce an act of the legislature. P. 327 U. S. 592.
(b) The word "statute" in § 266 is a compendious summary of various enactments, by whatever method they may be adopted, to which a State gives her sanction, and is at least sufficiently inclusive to embrace constitutional provisions. P. 327 U. S. 592.
3. Where a state attorney general has construed a provision of the state constitution as outlawing all closed shop agreements with
labor unions, has ordered law enforcement agencies to enforce it by criminal prosecution of labor unions, their officers and agents, and of employers having closed shop agreements, and has threatened and actually instituted quo warranto proceedings to cancel franchises of corporations having and observing closed shop agreements with labor unions, the situation involves a threat of "irreparable injury which is clear and imminent," so as to justify a federal court of equity in interfering with the enforcement of the state law notwithstanding § 267 of the Judicial Code, forbidding the maintenance of suits in equity in the federal courts "in any case where a plain, adequate, and complete remedy may be had at law." P. 327 U. S. 593.
(a) The disruption in collective bargaining which would be occasioned by holding closed shop agreements illegal would be so serious as to make it futile to attempt to measure the loss in money damages and any remedy at law in the federal courts would be inadequate. P. 327 U. S. 594.
(b) The announcement of the state attorney general of a policy to prosecute criminally all violators of the law involved, and the actual institution of quo warranto proceedings against several corporations having closed-shop agreements, make the threat real and imminent. P. 327 U. S. 594.
(c) The allegation that there is an imminent threat to an entire system of collective bargaining which, if carried through, will have such repercussions on the relationship between capital and labor as to cause irreparable damage states a cause of action in equity. P. 327 U. S. 595.
4. However, in such a situation, the federal district court should not pass on the merits of the controversy until the state constitutional provision has been authoritatively construed by the state courts. Pp. 327 U. S. 595-599.
(a) If it is construed so as to eliminate any conflict with the National Labor Relations Act, one of the constitutional questions alleged to exist in this case will disappear. P. 327 U. S. 598.
(b) If it is construed as doing no more than to grant an individual working man a cause of action if he is denied employment unless he joins a union or to make closed shop agreements unenforceable between the parties, no case or controversy raising the due process question would be presented by this suit, in which no individual working man is asserting rights against unions or employers and no union is seeking to enforce a closed shop agreement against an employer. P. 327 U. S. 598.
(c) If it is construed not to be self-executing, suits seeking to raise any constitutional question would be premature until the State supplies sanctions for its enforcement. P. 327 U. S. 598.
5. In such circumstances, the district court should retain the bill until a definite determination of the local law questions can be made by the state courts. P. 327 U. S. 599.
6. Notwithstanding the fact that one of the principal grounds asserted for equitable relief is the continuance of litigation in the state courts, the purpose of a suit to enjoin enforcement of the state law will not be defeated by retaining the bill pending determination of proceedings in the state courts, since the resources of equity are not inadequate to deal with the problem so as to avoid unnecessary friction with state policies while selective cases go forward in the state courts for an orderly and expeditious adjudication of the state law questions. P. 327 U. S. 599.
60 F.Supp. 1010 reversed, and the cause remanded.
Appellants sued to enjoin enforcement of a provision of the Florida constitution (quoted in the opinion) on the ground that it violated the First Amendment, Fourteenth Amendment, and the Contract Clause of Article I, § 10 of the Federal Constitution and was in conflict with the National Labor Relations Act and the Norris-LaGuardia Act.
A district judge granted a temporary restraining order and caused a three-judge court to be convened pursuant to § 266 of the Judicial Code.
The district court concluded that it had jurisdiction of the controversy, but, without determining whether there was equity in the bill or whether the case should be held until an authoritative interpretation of the Florida law by the courts could first be obtained, proceeded at once to a consideration of the constitutional questions. It held that the Florida law did not violate the First or Fourteenth Amendment or the Contract Clause of Article I, § 10 of the Federal Constitution, and that it would be time to consider any conflict with the National Labor Relations Act if and when it arose, since that Act and the Florida law did not, on their face, appear to be in conflict. It accordingly
vacated the temporary restraining order and dismissed the bill. 60 F.Supp. 1010.
Reversed and remanded, with directions to retain the bill pending determination of proceedings in the state courts in conformity with the opinion of this Court. P. 327 U. S. 599.
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