Ex Parte Young
209 U.S. 123 · Supreme Court of the United States · 1908
Facts
Stockholders of the Northern Pacific Railway Company initiated a suit because the state legislature and railroad commission had fixed freight and passenger rates. These state acts imposed enormous penalties, including large fines and lengthy imprisonment, for any disobedience by company officers, agents, or employees. The stockholders alleged that these rates were confiscatory and that the severe penalties effectively prevented the railway company from resorting to courts to determine the validity of the acts. The Attorney General of the State intended to enforce these provisions, which the stockholders contended would compel the company to obey the laws, even if such obedience ultimately led to the confiscation of its property.
Procedural history
Stockholders of the Northern Pacific Railway Company commenced a suit in the Circuit Court. The Circuit Court granted a temporary injunction against the enforcement of the commodity act, finding the rates confiscatory and the act unconstitutional. The Attorney General subsequently commenced proceedings to enforce the act despite the injunction, leading to a finding of contempt. The case reached this court via a petition for writs of habeas corpus and certiorari, seeking discharge from imprisonment for contempt.
Issue
Can a federal court enjoin a state attorney general from enforcing state laws alleged to be unconstitutional, particularly when such laws impose penalties so severe as to preclude judicial review? Does the Eleventh Amendment bar such a suit against a state officer?
Holding
Yes, a federal court can enjoin a state attorney general from enforcing an unconstitutional state law. The provisions of the state acts imposing enormous fines and imprisonment for attempting to test their validity are unconstitutional on their face. The Circuit Court had jurisdiction to inquire whether the rates were confiscatory and to enjoin their enforcement.
Rule
A state official enforcing an unconstitutional act is stripped of their official or representative character and is subjected in their person to the consequences of individual conduct, meaning a suit against them is not a suit against the state under the Eleventh Amendment. Federal courts have jurisdiction to enjoin state officers from enforcing unconstitutional state statutes that violate federal rights and cause irreparable damage. Laws that impose penalties so enormous and severe as to intimidate a company and its officers from resorting to the courts to test the validity of legislation are unconstitutional, as they effectively deny judicial review and due process by closing off access to the courts.
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