Cumberland Telephone & Telegraph Co. v. Louisiana Public Service Commission
Headline: Court blocks a single federal judge from keeping a temporary injunction that froze a state utility commission’s rate cut, and sends the decision about maintaining the status quo back to the three-judge court that heard the case.
Holding: The Court held that under §266 a single federal judge lacked power to continue an injunction against state officials after a three-judge court denied an interlocutory injunction, so the single-judge injunction was void and set aside.
- Stops a lone judge from continuing injunctions that block state agency actions.
- Refers requests to maintain the status quo to the three-judge court that heard the case.
- Makes three-judge participation required before such injunctions continue.
Summary
Background
A telephone company sued a state public service commission to stop it from cutting phone rates, saying the cuts would force the company to charge confiscatory prices and violate its Fourteenth Amendment rights. A District Judge first issued a short restraining order and a three-judge court later heard the request for an interlocutory injunction and denied it, with that same District Judge dissenting. Afterward the District Judge, sitting alone, allowed an appeal, issued a supersedeas, and continued the restraining order while requiring a $100,000 bond with conditions about repaying excess charges.
Reasoning
The core question was whether one federal judge can continue or vary an injunction against state officials after a three-judge court has acted. The Court relied on § 266 of the Judicial Code and earlier decisions to hold that a single judge lacks that power. The Court explained Congress intended such matters to be decided by a court of three judges to avoid improvident interference with state laws. Because the continuance of the restraining order was signed only by the single judge and not by the three-judge court, it was void and was set aside.
Real world impact
The ruling means requests to keep or extend injunctions against state officials after a three-judge decision must be handled by the three-judge court that reviewed the case. Bonds and appeals remain possible, but the single judge cannot unilaterally keep blocking state action. The Court did not decide the underlying rate dispute or the ultimate validity of the bond.
Dissents or concurrances
Judge Foster dissented from the three-judge denial and later acted alone to continue the injunction; the majority rejected that approach as unauthorized.
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