Hunter v. Wood

Background

A man named Wood, while obeying a federal court injunction in a separate case about railroad rates, sold tickets at the usual price and gave coupons as required by that injunction. While following the federal court’s order he was arrested, tried, and convicted in a state police court for violating a state law that fixed railroad rates. Detained under that state conviction, Wood sought a writ of habeas corpus from a federal circuit judge to challenge his custody.

Reasoning

The central question was whether a federal circuit judge could issue habeas corpus and free someone held for acts done in obedience to a federal court order. The Court relied on the federal statute cited (§ 753 of the Revised Statutes) and prior authority and held the writ was properly issued, that the judge had the duty to examine the facts, and that the judge had power to discharge the prisoner under those circumstances. The Court therefore affirmed the order discharging Wood.

Real world impact

This decision means people who are arrested by a state for complying with a federal court injunction can seek immediate relief in federal court by habeas corpus. It reinforces that federal courts can protect compliance with their orders even when state prosecutions follow. The decision was tied to earlier cases dealing with the same federal-versus-state conflict.

Dissents or concurrances

Justice Harlan dissented, arguing Wood should instead have sought review through the state’s highest court and then come to the United States Supreme Court, and that he should not have been discharged on habeas corpus.