Ex Parte Metropolitan Water Co. of West Virginia
Headline: Federal law limits single-judge power: Court ordered that a district judge lacked authority to decide an injunction against a Kansas statute alone and required a three-judge hearing, forcing the case to be reheard before multiple judges.
Holding:
- Requires three-judge panels for federal injunctions that block state statutes.
- Allows single judges only brief emergency restraining orders until the three-judge hearing.
- Makes mandamus available to undo single-judge orders when statute requires a three-judge hearing.
Summary
Background
A West Virginia corporation that owned riverfront land sued to stop a local drainage district in Wyandotte County, Kansas, from taking its property under a new Kansas law passed January 28, 1911. The law authorized the state to appropriate the lands and directed the Attorney General to bring proceedings to set compensation. The company filed for a federal injunction, and a single federal judge, acting as a circuit judge, issued a temporary restraining order on February 8, 1911. After hearing the judge vacated that order and denied the injunction on March 6, 1911.
Reasoning
The Court focused on §17 of the Act of June 18, 1910, which says requests to block the enforcement of a state statute by stopping state officers must be heard by three judges, including at least one circuit judge or Supreme Court Justice. The Court explained that Congress limited a single judge’s power in such cases: a single judge may issue a brief emergency restraining order but must call two other judges to hear the application for an interlocutory injunction. Because the federal judge had decided the injunction motion alone, his order denying the injunction was void for lack of jurisdiction. The Supreme Court therefore refused to decide whether the Kansas law was constitutional and instead granted mandamus to undo the single-judge order and require a three-judge hearing.
Real world impact
Lower courts must follow §17 when a party asks to block a state statute by stopping state officers: emergency restraining orders by one judge are temporary only, and the full three-judge panel must hear and decide the injunction. The ruling sent the case back for a rehearing before three judges and emphasized that appeals in such matters must come after the required three-judge hearing. This decision changed how federal courts process immediate challenges to state statutes in similar circumstances.
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