## Facts

- Minnesota enacted intrastate railroad rate statutes with severe civil and criminal penalties for noncompliance, including heavy fines and imprisonment.
- Railroad shareholders alleged the rates were confiscatory and that the penalty scheme effectively prevented judicial review, violating the Fourteenth Amendment.
- Before the statutes took effect, shareholders sued in federal circuit court seeking to enjoin state officials, including the Minnesota Attorney General, from enforcing the statutes.
- The federal court issued a temporary injunction restraining the Attorney General from taking enforcement steps to impose penalties.
- The next day, the Attorney General initiated a Minnesota enforcement proceeding to compel compliance, contrary to the federal injunction.
- The federal court held the Attorney General in contempt and committed him to custody.
- The Attorney General petitioned the U.S. Supreme Court for habeas corpus and certiorari, arguing the injunction was void because the Eleventh Amendment barred the underlying suit.

## Issues

1. Whether an injunction suit against a state attorney general to stop enforcement of allegedly unconstitutional state statutes is barred by the Eleventh Amendment as a suit against the State.
2. Whether the constitutional claims regarding confiscatory rates and deterrent penalties presented a federal question sufficient for federal court jurisdiction.
3. Whether the contempt commitment was lawful or void for lack of jurisdiction in the underlying injunction action.

## Decision

- The Supreme Court denied relief and upheld the federal court’s jurisdiction, the temporary injunction, and the contempt commitment.
- The Court held that the Eleventh Amendment did not bar prospective injunctive relief against a state officer enforcing an unconstitutional statute.
- The Court found the allegations about confiscatory rates and penalties that deter judicial review raised substantial federal constitutional questions supporting federal jurisdiction.
- Because the federal court had jurisdiction, its injunction was valid and the Attorney General could be punished for contempt for violating it.
- Justice Harlan dissented, concluding the suit was effectively against the State and therefore outside federal judicial power under the Eleventh Amendment.

## Legal Principles

- A federal court may grant prospective injunctive relief against a state official to prevent enforcement of a state law alleged to violate the U.S. Constitution.
- For Eleventh Amendment purposes, a state officer attempting to enforce an unconstitutional law is treated as acting without lawful state authority and may be sued in federal court for injunctive relief.
- Allegations that statutory penalties are so severe that they deter access to judicial review can present a federal due process question supporting federal jurisdiction.
- A contempt order for violating a federal injunction is valid when the issuing court had subject-matter jurisdiction and authority to enter the injunction.

## Conclusion

The Court held that the Eleventh Amendment does not prevent federal courts from enjoining state officials from enforcing unconstitutional state laws, and it sustained the contempt commitment because the federal court had jurisdiction to issue and enforce its injunction.


Ex parte Young, 209 U.S. 123 (1908)