Ex Parte Northern Pacific Railway Co.
Headline: Court stops a single judge from dismissing a railroad challenge to a Montana rate order and orders a three-judge panel to hear the injunction request, protecting plaintiffs’ statutory right to a three-judge hearing.
Holding: The Court ordered that a single district judge lacked authority to dismiss the case or dissolve the temporary restraining order and directed that a three-judge court be assembled to hear the injunction application.
- Prevents a lone judge from dismissing cases requiring a three-judge panel.
- Orders district courts to assemble three judges to hear injunction requests under the statute.
- Restores procedural protections for plaintiffs challenging state rate orders.
Summary
Background
A group of railroad companies sued Montana’s railroad regulators to stop enforcement of a state rate order, saying the order conflicted with the Constitution’s commerce clause and federal commerce laws. They asked a federal judge for a temporary restraining order and later for an interlocutory injunction. One judge (Judge Pray) granted a temporary restraining order that would remain until a three-judge court could hear the injunction. Before that three-judge court was assembled, another judge (Judge Bourquin), sitting alone, considered motions to dissolve the restraining order and to dismiss the case, and he dismissed the suit.
Reasoning
The Court considered whether a single district judge could dissolve the restraining order or dismiss the suit while the request for a three-judge hearing was pending. Relying on the statute requiring three judges (28 U.S.C. §380 as amended) and prior decisions, the Court held that the statute required a three-judge court to hear and decide such matters. Because the injunction request had not been withdrawn and was actively pursued, a lone judge had no authority to rule on the motions. The Court therefore made its rule absolute, ordered the dismissal vacated, and directed immediate steps to assemble a three-judge court to hear the injunction request.
Real world impact
The decision enforces the statutory right to a three-judge panel in important federal challenges, preventing a single judge from deciding those matters. It sends the case back to the district court with instructions to convene three judges so the injunction request can be heard according to the statute.
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