Ex Parte Poresky
Headline: Court denies order forcing a three-judge panel and allows a single judge to dismiss a Massachusetts driver’s constitutional challenge to compulsory car-insurance law, leaving state registration enforcement in place.
Holding: The Court denied the mandamus petition and held that a single district judge may dismiss a suit for lack of federal jurisdiction when no substantial constitutional question is presented.
- Lets single federal judges reject constitutionality challenges that are clearly without merit.
- Denies immediate three-judge hearing and injunction for the Massachusetts driver.
- Leaves state vehicle-registration enforcement intact pending any further review.
Summary
Background
A Massachusetts driver sued the state’s governor, attorney general, and the motor vehicle registrar to stop enforcement of a state law that requires posting $5,000 bond or getting car liability insurance before registering a car. The driver said the law violates the Fourteenth Amendment and that the registrar refused registration and plates because he could not comply. The district judge dismissed the governor and attorney general for improper joinder and then dismissed the registrar’s case for lack of federal jurisdiction because there was no diversity of citizenship and no substantial federal constitutional question.
Reasoning
The core issue was whether a single federal judge must call a three-judge court to consider an injunction against the state law. The Court explained that the rule requiring three judges assumes the federal court has jurisdiction in the first place. A single judge must decide from the complaint whether a substantial constitutional question is actually presented. If the claimed constitutional issue is plainly unsubstantial or clearly foreclosed by prior decisions, the single judge may dismiss for lack of jurisdiction. Applying those principles and earlier cases, the Court found no basis to compel a three-judge hearing here.
Real world impact
The Supreme Court denied the petition for a writ of mandamus, so the petitioner did not get the three-judge panel or an interlocutory injunction. Practically, that means the state’s registration requirement remains enforceable against this driver unless further review or a different legal route succeeds. The decision is procedural: it upholds a judge’s power to refuse a multi-judge hearing when the constitutional claim appears unsubstantial.
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