## Facts

- Wycoff Company, Inc. transported motion-picture film and newsreels to and within Utah under authority issued by the Interstate Commerce Commission.
- Wycoff treated its transportation between Utah points as part of a continuous interstate movement and claimed state regulation would be preempted.
- Wycoff sued the Utah Public Service Commission in federal district court seeking (1) a declaration that its Utah-point-to-Utah-point carriage was interstate commerce and (2) an injunction barring the Commission from interfering with those operations.
- Wycoff alleged the Commission threatened to stop or obstruct its transportation; the Commission denied any attempt or intent to interfere with interstate commerce.
- After trial, the district court dismissed the complaint, finding no evidence of past, pending, or threatened Commission action affecting Wycoff’s business.
- The court of appeals reversed, treating the dispute as whether the intrastate legs were integral parts of interstate transportation.
- The Supreme Court granted review and reversed.

## Issues

1. Whether equitable relief by injunction is available where there is no proof of threatened or probable state action causing irreparable injury.
2. Whether a federal court should issue a declaratory judgment on the interstate character of transportation when no concrete, imminent state enforcement action creates an immediate dispute.
3. In an anticipatory declaratory-judgment suit asserting a federal defense to possible state proceedings, whether federal-question jurisdiction depends on the federal defense or on the nature of the threatened state action.

## Decision

- The Supreme Court reversed the court of appeals.
- Injunctive relief was unavailable because the record showed no threatened or probable Commission action and thus no basis for irreparable-injury equity jurisdiction.
- The action should not proceed as a declaratory-judgment case because there was no immediate, definite controversy and the requested declaration would improperly preempt state administrative and judicial processes.
- For federal-question jurisdiction in anticipatory declaratory suits, “the character of the threatened action, and not of the defense,” controls.

## Legal Principles

- Injunctions against state regulatory officials require proof of threatened or probable action creating irreparable injury; speculative future enforcement is insufficient.
- The Declaratory Judgment Act is discretionary and authorizes relief only in an actual controversy permitting an immediate and definite determination of legal rights.
- Federal courts should not use declaratory relief as a “stand-by” ruling for potential future disputes or to “pre-empt and prejudge” matters committed in the first instance to state administrative bodies and state review procedures.
- When a declaratory-judgment complaint effectively anticipates a federal defense to prospective state proceedings, federal-question jurisdiction is determined by the nature of the threatened state claim, not by the anticipated defense.

## Conclusion

The Court held that, absent a concrete threat of state enforcement, Wycoff could not obtain an injunction and should not receive a declaratory judgment that would function as an advisory ruling and improperly displace state regulatory decisionmaking; jurisdiction in such anticipatory actions turns on the threatened state proceeding rather than the federal defense.


Pub. Serv. Comm'n of Utah v. Wycoff Co., 344 U.S. 237 (1952)