## Facts

- The Delaware Department of Labor & Industrial Relations (the Department), a state administrative agency, sought to assert labor-relations jurisdiction over the Delaware Family Court (the Family Court).
- The Department attempted to require collective bargaining between the Family Court and a union representing Family Court employees.
- The Family Court disputed that the Department had authority to treat the judicial branch (and the Family Court in particular) as an “employer” subject to the Department’s labor-relations process.
- The Family Court filed an action in the Delaware Court of Chancery seeking a declaratory judgment that the Department lacked jurisdiction to compel collective bargaining involving the Family Court.
- Because Chancery is a court of equity, the court examined whether a writ of prohibition was an available and adequate remedy at law that would require the dispute to proceed in a court of law rather than in equity.

## Issues

1. Whether the availability of a writ of prohibition as a remedy at law barred the Court of Chancery from hearing the Family Court’s declaratory judgment action challenging the Department’s asserted jurisdiction.
2. If Chancery could proceed, whether the Department had statutory authority to exercise labor-relations jurisdiction over the Family Court and require bargaining with the employees’ union.

## Decision

- The Court of Chancery focused on the threshold question of equitable jurisdiction rather than resolving the underlying labor-jurisdiction dispute on the merits.
- The court concluded that a writ of prohibition was the type of legal remedy designed to prevent a tribunal or agency from proceeding without jurisdiction.
- Because that legal remedy was available and adequate for the relief sought, the court determined that equitable declaratory relief in Chancery was not appropriate.
- The court therefore declined to decide the merits of the Department’s claimed labor jurisdiction in Chancery and directed that the matter proceed in a court of law (via the remedy of prohibition rather than equitable declaratory relief).

## Legal Principles

- The Court of Chancery, as a court of equity, generally will not grant relief (including declaratory relief) when an adequate remedy at law exists.
- A writ of prohibition is a legal remedy used to restrain a tribunal or agency from acting beyond its jurisdiction, particularly when the harm would be the continuation of an unauthorized proceeding.
- When the plaintiff’s requested relief is effectively to stop allegedly ultra vires action and prohibition is available, the presence of that legal remedy can defeat equity jurisdiction and require the case to proceed in a law forum.

## Conclusion

Family Court v. Department of Labor & Industrial Relations addresses a separation-of-powers dispute arising from an executive labor agency’s attempt to compel collective bargaining involving judicial employees, and it resolves the matter in Chancery on jurisdictional grounds by treating prohibition as an adequate legal remedy that displaces equitable declaratory relief.


Family Court v. Department of Labor & Industrial Relations, 320 A.2d 777 (1974)