Kennington v. Palmer
1921 U.S. LEXIS 1797 · 255 U.S. 100 · 41 S. Ct. 304 · 65 L. Ed. 528
February 28, 1921 · Docket 367
Headnotes
Generated summaries- Headnote 1
The dealers in Jackson, Mississippi filed a bill in equity to enjoin enforcement of § 4 of the Lever Act, asserting the provision was unconstitutional. The Court held, based on Cohen Grocery Co., that the unconstitutionality claim was well‑founded and therefore warranted injunctive relief.
- Headnote 2
The district court dismissed the dealers’ equity claim because it believed a legal remedy was sufficient. The Supreme Court reversed, holding that the dismissal was improper where the underlying claim challenges the constitutionality of the statute.
- Headnote 3
The lower court relied on the traditional rule that an adequate legal remedy precludes equitable relief. This case distinguished that rule, holding that a well‑founded claim of unconstitutionality overrides the adequate‑remedy defense.
- Headnote 4
The dealers argued that § 4 of the Lever Act was unconstitutional, relying on the Cohen Grocery decision. The Court held that the unconstitutionality claim was well‑founded and therefore justified injunctive relief, reversing the lower court’s dismissal.
- Headnote 5
The district court dismissed the dealers’ equity suit because it believed a legal remedy was sufficient. The Supreme Court reversed, holding that the presence of a legal remedy does not bar equitable relief where the plaintiff challenges the constitutionality of the statute.
- Headnote 6
The trial court dismissed the dealers’ bill in equity on the ground that an adequate legal remedy existed, but the Supreme Court held that because the unconstitutionality claim was well founded under Cohen Grocery, the dismissal was erroneous and reversed.
- Headnote 7
The dealers relied on the unconstitutionality of § 4 of the Lever Act, a contention previously affirmed in Cohen Grocery; the Court held that such a claim justifies injunctive relief and reversed the lower court’s dismissal.
- Headnote 8
The dealers claimed § 4 of the Lever Act was unconstitutional, relying on the precedent in Cohen Grocery Co. The Court held that because that precedent established the claim as well‑founded, the lower court’s dismissal was erroneous and the injunction claim may proceed.
- Headnote 9
The district court dismissed the dealers’ equity bill because it believed a legal remedy sufficed. The Supreme Court reversed, finding that the unconstitutionality claim warranted equitable relief and that the dismissal was improper.
- Headnote 10
The lower court dismissed the equity claim on the basis that the dealers could obtain relief at law, applying the traditional adequate‑remedy rule.
- Headnote 11
Citing Cohen Grocery Co., the Court held that a properly founded allegation that a statute is unconstitutional justifies equitable relief, leading to reversal of the dismissal.
- Headnote 12
The Jackson, Mississippi dealers filed a bill in equity to enjoin enforcement of § 4 of the Lever Act, asserting unconstitutionality grounded in the Cohen Grocery decision. The Supreme Court held that the unconstitutionality claim justified injunctive relief despite the existence of a legal remedy.
- Headnote 13
The district court dismissed the dealers’ equity action because it said an adequate legal remedy existed. The Supreme Court reversed, holding that dismissal was improper where the plaintiff seeks injunctive relief based on a well‑founded constitutional challenge.
- Headnote 14
Although the adequacy of a legal remedy normally bars equitable relief, the Court held that a plaintiff’s successful constitutional challenge—affirmed by Cohen Grocery—provides an independent ground for injunction, overriding the usual doctrine.
- Headnote 15
The Court reversed the district court’s dismissal of a bill in equity, finding that the unconstitutionality claims were well founded under Cohen Grocery Co. and therefore justified equitable relief.
- Headnote 16
The lower court dismissed the bill because it believed an adequate legal remedy existed, but the Supreme Court held that the unconstitutionality allegation created a right to equitable relief, so the dismissal was improper.
Opinion
delivered the opinion of the court.
The appellants, dealers in wearing apparehin the city of Jackson, Mississippi, filed their bill in the court below against the Attorney General and subordinates charged by him with administrative duties under § 4 of the Lever Act to enjoin the enforcement against them of provisions of that section. Their right to relief was based upon averments as to the unconstitutionality of the assailed provisions of the section, not only, in substance, upon the contentions which we have this day considered and disposed of in the Cohen Grocery Co. Case, ante, 81, but upon other grounds as well.
Without passing upon the question of constitutionality, the court dismissed the bill for the reason that the complainants had an adequate remedy at law, and the correctness of the decree of dismissal is the question now before us on direct appeal.
As it is no longer open to deny that the averments of unconstitutionality which were relied upon, if wel' founded, justified equitable relief under the bill, 1 .anc because the opinion in the Cohen Case has conclusively' settled that they were well founded, -it follows that the court below was wrong and its décree must be and it is reversed and the case remanded for further proceedings in conformity with this opinion.
Reversed.
Wilson v. New, 243 U. S. 332; Adams v. Tanner, 244 U. S. 590; Hammer v. Dagenhart, 247 U. S. 251; Hamilton v. Kentucky Distilleries Co., 251U. S. 146; Ruppert v. Caffey, 251 U. S. 264; Ft. Smith & Western R. R. Co. v. Mills, 253 U. S. 206.