Atlantic Coast L. R. Co. v. Brotherhood of Locomotive Engineers, 398 U.S. 281 (1970)
Unless an injunction is authorized by Congress, necessary to further the court's jurisdiction, or needed to protect or enforce the court's judgment, a federal court cannot enjoin a state court proceeding under the Anti-Injunction Statute.
Atlantic Coast Line R.R. sought an injunction in federal court against the picketing activities of the Brotherhood of Locomotive Engineers, which was picketing a railroad yard in Florida that Atlantic owned and operated. After the federal court denied the injunction, Atlantic successfully received it in state court. Two years later, in the Jacksonville Terminal case, the Supreme Court ruled that unions have a federally protected right to picket that state court injunctions may not infringe. Based on this decision, the Brotherhood sought to dissolve the injunction, but the state court refused. Rather than appealing the denial of that request, the Brotherhood sought and received an injunction in federal court against the enforcement of the state court injunction.Opinions
- Hugo Lafayette Black (Author)
- Warren Earl Burger
- William Orville Douglas
- Potter Stewart
- Thurgood Marshall
Neither party claims that Congress has authorized the federal court injunction. Moreover, it was not a proper way to protect or give effect to the federal court's earlier order, or to aid its jurisdiction. Appealing a state court decision in a federal district court is not an appropriate strategy, and the Brotherhood essentially was doing that when it asked the federal judge to determine that the state judge erred in distinguishing the Supreme Court case. In this situation, state and federal courts have concurrent jurisdiction, and neither can prevent the parties from pursuing simultaneous claims in both courts. No injunction thus was needed to aid the jurisdiction of the federal court, since it was not undermined by the federal preclusion issue and the state court's ability to resolve the state law claims.
- William Joseph Brennan, Jr. (Author)
- Byron Raymond White
The Anti-Injunction Statute is designed to prevent state courts from undermining a prior judgment of a federal court, which is the situation here. The right granted by a federal court (the Supreme Court) to the union has been nullified by the injunction against picketing that the state court granted.
- John Marshall Harlan II (Author)
This area often involves the doctrine of pre-emption, since Congress has regulated it so heavily that the state courts often lack authority to issue injunctions.
U.S. Supreme CourtAtlantic Coast L. R. Co. v. Engineers, 398 U.S. 281 (1970)
Atlantic Coast L. R. Co. v. Brotherhood of Locomotive Engineers
Argued March 2-3, 1970
Decided June 8, 1970
398 U.S. 281
As part of its dispute with the Florida East Coast railroad (FEC) respondent Brotherhood of Locomotive Engineers (BLE) in 1967 began picketing a switching yard owned and operated by Atlantic Coast Line railroad (ACL). ACL's request for an injunction to halt the picketing was denied by the Federal District Court, which held that the BLE was "free to engage in self-help," and that the Norris-LaGuardia Act and § 20 of the Clayton Act were applicable. ACL then obtained an injunction from a Florida court. After the decision in Railroad Trainmen v. Jacksonville Terminal Co., 394 U. S. 369 (1969), holding that unions had a federally protected right to picket the terminal without interference by state court injunctions, respondent union moved in state court to dissolve the injunction, but the state judge held that Jacksonville Terminal was not controlling, and denied the motion. The union then returned to the District Court and requested an injunction against the enforcement of the state injunction, which the District Court granted. The Court of Appeals affirmed. The union contends that the federal injunction was proper under 28 U.S.C. § 2283 either "to protect or effectuate" the District Court's 1967 denial of an injunction, or as "necessary in aid of" that court's jurisdiction.
Held: The federal injunction was not justified under the exceptions in § 2283, and thus was improperly issued in this case. Pp. 398 U. S. 285-297.
(a) A federal injunction against state court proceedings otherwise proper under general equitable principles must be based on one of the specific statutory exceptions to § 2283. Amalgamated Clothing Workers v. Richman Bros., 348 U. S. 511, 348 U. S. 515-516. Pp. 398 U. S. 286-287.
(b) The District Court's determination in 1967 that the union had a right to "engage in self-help" under federal law, was not a decision that federal law precluded an injunction based on state law. Pp. 398 U. S. 289-291.
(c) In 1969, the union, in effect, was attempting to get the District Court to decide that the state court erred in distinguishing Jacksonville Terminal, but such attempt to seek federal appellate review of a state decision cannot be justified as necessary "to protect or effectuate" the 1967 order. Pp. 398 U. S. 291-293.
(d) Since the state and federal courts had concurrent jurisdiction in this case neither court could prevent a party from simultaneously pursuing claims in both courts, and an injunction was not "necessary in aid of" the District Court's jurisdiction because the state court may have acted improperly in light of Jacksonville Terminal, as the state court's assumption of jurisdiction over the state law claims did not hinder the federal court's jurisdiction. Pp. 398 U. S. 294-296.
(e) While the union cannot obtain direct review of the state court decision in the lower federal courts, it can, if adversely affected by the decision or if faced with immediate irreparable injury, seek relief in the Florida appellate courts, and possibly in this Court. P. 398 U. S. 296.
Reversed and remanded.