Houghton v. Meyer

Background

A publishing company sued the Postmaster General after he reclassified its series and charged higher postage. The publishers obtained a temporary restraining order that let them send the books at the lower rate, but only after giving an indemnity bond. The lower court later granted a permanent injunction for the publishers, which was reversed on appeal and affirmed by this Court, leaving the question whether the bond required repayment for the entire litigation period.

Reasoning

The Court examined the statute authorizing temporary restraining orders and the exact terms of the undertaking the publishers gave. It explained that a statutory restraining order is meant to preserve the status quo only until the pending motion can be decided. Because the permanent injunction that followed superseded the temporary restraining order, the Court held the bond was given only to secure the brief restraining-order period. The Court distinguished earlier cases that permit broader relief on equity grounds, and therefore limited liability under the bond to the time before the District Court’s March 10, 1903 decree.

Real world impact

The ruling lets the Government recover postage the publishers improperly saved only for the narrow period the temporary restraining order ran, not for the entire appeals process. Publishers and their sureties are not liable under this bond for postage charged after the restraining order’s approved period ended. The Court modified the lower-court judgment to reflect that limited recovery.