Robertson v. Railroad Labor Board

Background

The Railroad Labor Board issued a subpoena under the Transportation Act of 1920 ordering Robertson, a Cleveland resident, to appear in Chicago to testify in a labor dispute. Robertson was served in Cleveland, did not attend personally, and through counsel challenged the Board’s jurisdiction. The Board sued in the federal court for northern Illinois to force compliance. The Illinois court ordered Robertson to appear despite his objections, and the question whether that court had power over him was brought to this Court.

Reasoning

The central question was whether Congress’s phrase “any United States district court” allowed the Board to pick any federal court and force an out-of-district person to litigate there. The Court explained the ordinary rule: a federal district court has in-person power only over persons who live in or are found in its district, unless Congress clearly provides otherwise. The Court found no clear congressional language extending a district court’s reach to every part of the country. Because Congress had not plainly granted that extraordinary power, the phrase means a district court of competent personal jurisdiction and the Illinois decree could not stand.

Real world impact

The decision prevents administrative boards from using chosen venues to compel people who live elsewhere to litigate in distant districts. Boards may still hold hearings anywhere and issue subpoenas, but federal courts may enforce those subpoenas only when they have personal authority over the person. This ruling narrows how the Labor Board and similar agencies can secure evidence from remote witnesses and reverses the Illinois court’s order.