## Facts

- Anway worked as a street railway conductor for Grand Rapids Railway Company.
- He filed suit seeking only a declaratory judgment construing a 1919 statute regulating street railway employees’ workdays (whether employees could be allowed to work more than six days in any consecutive seven-day period).
- He alleged no breach of contract, no violation of a vested right, and no past or present injury or damages.
- No enforcement action or concrete dispute over liability or coercive relief was pending; the suit sought advance statutory interpretation.

## Issues

1. Whether Michigan’s 1919 declaratory judgments statute, authorizing “merely declaratory” judgments without consequential relief, was constitutional under the Michigan Constitution.
2. Whether a request for prospective statutory interpretation, without an actual or threatened invasion of rights, presents a judicial controversy within the courts’ power to decide.
3. If the action were cognizable, whether the workdays statute barred permitting conductors and motormen to work more than six days in seven.

## Decision

- The Michigan Supreme Court held the 1919 declaratory judgments statute unconstitutional (Sharpe and Clark, JJ., dissenting).
- The court concluded the statute required courts to exercise nonjudicial power by issuing declarations untethered to traditional judicial relief.
- Because the action presented no justiciable controversy, the court dismissed the proceeding and did not reach the statutory-interpretation question regarding the workdays law.

## Legal Principles

- State courts may exercise only judicial power as defined by the state constitution; the legislature cannot confer authority to render advisory opinions.
- A justiciable controversy generally requires an actual, concrete dispute concerning existing or threatened legal rights, not a purely hypothetical request for statutory construction.
- A declaratory-judgment procedure that compels adjudication without an enforceable dispute or consequential relief may be unconstitutional as nonjudicial in character.

## Conclusion

The court refused to interpret the workdays statute because the suit sought only an abstract declaration without any present injury or enforceable dispute; it held the declaratory judgments act unconstitutional for authorizing advisory, nonjudicial determinations and dismissed the case for lack of a justiciable controversy.


Anway v. Grand Rapids Ry. Co., 211 Mich. 592 (1920)