Pullman Co. v. Croom

Background

A private company (the Pullman Company) sued state officers to stop state tax collection and asked for temporary injunctions. The suits were filed under the federal rule that such injunction requests be heard by a three-judge court and allow direct appeal to this Court. The Comptroller named in the suits, A. C. Croom, died while the cases were pending, and the lower court had ordered a substitution of parties that included the state Treasurer, though no injunction had been sought against the Treasurer.

Reasoning

The key question was whether the Court could proceed on direct appeals from orders denying temporary injunctions when the named state official who was the target of the injunction had died. The Court reviewed earlier decisions holding that actions against officials are personal and that successors cannot be substituted for state officers absent a statute allowing it. Congress had passed a law in 1899 allowing substitution for Federal officers, but that statute does not cover state officials. Because no statute authorized substituting the state Comptroller’s successor, and there was no final judgment, the Court concluded there was no proper appellee to stand in judgment on the interlocutory injunction orders.

Real world impact

The Court therefore vacated the earlier substitution order and dismissed the direct appeals for lack of a proper appellee. Practically, the denial of the temporary injunction remains not reviewed by this Court on that appeal, and the underlying case continues subject to the control of the lower court and further proceedings.