Howat v. Kansas

Background

A Kansas law created a Court of Industrial Relations to investigate and set wages, returns to capital, and working conditions in certain industries. In one case several miners were subpoenaed to testify before that tribunal, refused to appear, and were jailed for contempt. In the other case about 150 local union members were enjoined from calling strikes in several counties, and some were later found to have directed a strike and were sentenced to prison for contempt. The opinion describes the tribunal as an administrative body with power to summon witnesses and make orders and notes the law targets strikes, lockouts, and related conduct.

Reasoning

The core question was whether the Kansas law violated the Federal Constitution. The Supreme Court refused to decide those constitutional questions because the Kansas courts had disposed of the cases on ordinary state-law grounds — namely the power of a court of general jurisdiction to issue subpoenas and injunctions and to punish disobedience. The Kansas court also relied on a severability clause saying any invalid provision could be disregarded and on prior authority that courts may compel witnesses for investigations; because the state decisions rested on these general principles, the high court dismissed review and would not reach the constitutionality issues.

Real world impact

The ruling means people must obey apparent court orders and cannot avoid compliance by asserting the underlying law is unconstitutional in that moment; challenges to the law must proceed through appeal rather than by disobedience. The Supreme Court did not finally decide whether the Industrial Relations law itself is constitutional, so that separate question remains for future proceedings.