United States v. Johnson

Background

A tenant brought suit against his landlord claiming the building lay in a wartime rent‑control area and that the landlord charged more than the maximum set by the Administrator under the Emergency Price Control Act of 1942. The tenant sought treble damages and attorney fees. The United States intervened to defend the law. The district court dismissed the case, ruling the Act an unconstitutional delegation of legislative power, and the Government moved to reopen and dismiss the case as collusive, a motion the court denied. The Government appealed.

Reasoning

The Court examined whether the litigation was a genuine adversary dispute. Affidavits showed the tenant had brought the suit as a 'friendly' action at the landlord’s request, did not hire or meet his attorney, did not pay fees, and did not control the case. The Court explained that where one party dominates a suit, courts should not resolve important constitutional questions that affect the public welfare. Because this proceeding lacked honest adverseness, the Court held the lower court should not have decided the law’s constitutionality and vacated the judgment, ordering the district court to dismiss the case as collusive. The opinion also directs that costs be handled under the governing statute.

Real world impact

This decision prevents courts from resolving major public‑interest constitutional questions in one‑sided, arranged lawsuits. It makes clear that parties must present real, opposing positions before a court may decide the validity of a statute. The Court’s action is procedural and leaves the underlying constitutional question undecided in a genuinely adversary proceeding.