Phillips v. United States

Background

A federal agency was building a dam in Oklahoma with U.S. funds when the Governor declared martial law over part of the dam site and obtained a state court order stopping work. The United States sued in federal court and a three-judge district court issued an interlocutory injunction restraining the Governor and other state officials from interfering.

Reasoning

The core question was whether the special three-judge procedure in § 266, which allows direct appeal to the Supreme Court, applied. The Court explained that Congress intended that special procedure only for suits challenging the enforcement of a state statute or an order made by a state administrative board. Because the United States challenged the Governor’s particular use of power, not the constitutionality of an Oklahoma statute or an administrative order, the case did not fall within § 266 and so was not eligible for direct Supreme Court review under the narrow statute.

Real world impact

The Court vacated the injunction and sent the case back so the district court can enter a fresh decree allowing a timely appeal to the circuit court. This is a procedural ruling, not a decision on whether the Governor’s actions were lawful; it preserves the ordinary appeals path for disputes about individual official actions and confines the special three-judge procedure to challenges to state statutes or administrative orders.