Facts
- Domestic & Foreign Commerce Corp. contracted with the War Assets Administration to purchase surplus coal owned by the United States.
- The Administration refused to deliver the coal to the buyer and entered a later agreement to sell the same coal to others.
- The buyer claimed the contract required payment only upon delivery of shipping documents and that it had not breached the agreement.
- The Administration construed the contract to require advance deposit of funds; when the buyer provided an unsatisfactory letter of credit instead, the Administration treated the buyer as in breach and resold the coal.
- The suit named the War Assets/Surplus Property Administrator in his official capacity and sought an injunction barring delivery to third parties and a declaration validating the original sale.
- The complaint did not allege that the contract was personal to the Administrator, that he exceeded statutory limits, or that his conduct effected an unconstitutional taking.
Issues
- Whether a suit seeking injunctive and declaratory relief against a federal officer, based on a contract with the United States, is in substance a suit against the United States requiring its consent.
- When, if ever, specific relief may proceed against a federal officer personally on the theory that the officer’s conduct is “illegal” for sovereign-immunity purposes.
Decision
- The Supreme Court reversed the court of appeals and held the district court lacked jurisdiction.
- The requested injunction and declaration would operate against the United States by compelling or restraining governmental action regarding government property and contract performance.
- Because the Administrator’s challenged conduct fell within his statutory authority and no constitutional defect was alleged, the suit could not proceed without a waiver of sovereign immunity.
- The court of appeals’ approach tying jurisdiction to whether title had passed was rejected; the controlling inquiry is whether the relief sought is, in effect, relief against the sovereign.
Legal Principles
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A suit nominally against a federal officer is treated as a suit against the United States when the relief sought would, in practical effect, control the government’s actions or disposition of its property.
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The central inquiry is whether the relief sought is relief against the sovereign, not the caption of the case or the merits of the underlying dispute.
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If an officer acts within valid statutory authority, the act is attributable to the sovereign for purposes of specific relief, even if the act would be wrongful under general law.
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Specific relief against an officer may proceed only when:
- the officer’s action is beyond statutory power (ultra vires), or
- the statutory authority, or its exercise in the particular case, is constitutionally void.
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Absent one of these exceptions or a congressional waiver, courts lack jurisdiction to order specific relief that would compel or restrain the United States.
Conclusion
The Court held that an injunction and declaratory judgment compelling delivery of government coal under a federal contract was, in effect, relief against the United States and therefore barred by sovereign immunity absent consent, unless the plaintiff plausibly alleged ultra vires or unconstitutional officer action.