Boise Artesian Hot & Cold Water Co. v. Boise City
Headline: Water company’s equity suit dismissed; Court affirms refusal to enjoin Boise’s $300 monthly license fee, leaving the company to fight collection through ordinary state-court remedies or timely removal to federal court.
Holding:
- Prevents federal courts from halting city fees without concrete irreparable harm.
- Requires companies to raise constitutional defenses in state suits or timely remove to federal court.
- Limits equity’s use to block local fiscal measures absent clear, documented injury.
Summary
Background
A West Virginia corporation supplied Boise, Idaho, with water under city ordinances allowing pipes in streets. The company says those ordinances created long-term franchises; the city calls them revocable permissions. On May 31, 1906, Boise passed an ordinance requiring the company to pay $300 each month as a license fee. The company went to federal equity court seeking an injunction to block the fee and to recover unpaid hydrant charges.
Reasoning
The core question was whether a federal court of equity should prevent the city from collecting the fee, or whether the company’s complaints must be handled in ordinary lawsuits. The Court held the company’s objections — that the fee was illegal or unconstitutional — are matters for a court of law, not equity. Equity will not enjoin state fiscal measures absent special circumstances such as irreparable injury, a multiplicity of suits, or a lien that clouds title. The bill alleged threats but gave no concrete facts, so equitable relief was not available.
Real world impact
The decision leaves the water company to defend against Boise’s collection suit in state court (or to remove it to federal court if timely). Municipalities may enforce local license or fee ordinances while constitutional defenses proceed in regular lawsuits. The Court did not decide the license fee’s constitutionality on the merits; it only held that federal equity was not the proper forum for a preventive injunction here.
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