Public Service Co. of Northern Ill. v. Corboy

Background

An Indiana law of 1907 let county authorities and a circuit court create drainage districts and authorize construction projects, including appointing a drainage commissioner to carry out the work. After the circuit court established a district and authorized a ditch from the Little Calumet River to Lake Michigan, an Illinois corporation that owns an electrical power plant on the Little Calumet sued a drainage commissioner in federal court. The company said the ditch would drain so much water from the interstate river that its Illinois plant would be seriously harmed, and it asked a federal court to block the work.

Reasoning

The lower federal court dismissed the company’s bill for lack of jurisdiction under §265 of the Judicial Code, which bars federal injunctions that would stay proceedings in state courts. The Supreme Court reviewed whether that statute prevented the federal court from hearing a suit to enjoin a state officer enforcing a state law. Relying on earlier decisions, the Court explained that federal courts may enjoin state officers acting under color of state law when constitutional rights are at stake and that §265 does not bar relief when the challenged action is not the kind of state judicial proceeding the statute protects. The Court reversed the dismissal and sent the case back to the lower court for further proceedings.

Real world impact

The ruling allows the federal court process to proceed so the Illinois company can try to prove its constitutional and property claims. It means federal courts can sometimes block state-authorized projects that allegedly harm out-of-state property rights. The case was not finally decided on the merits and must be decided below on the company’s factual and legal claims.