319 U.S. 293 (1943), 849, Great Lakes Dredge & Dock Co. v. Huffman

Docket Nº:No. 849
Citation:319 U.S. 293, 63 S.Ct. 1070, 87 L.Ed. 1407
Party Name:Great Lakes Dredge & Dock Co. v. Huffman
Case Date:May 24, 1943
Court:United States Supreme Court

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319 U.S. 293 (1943)

63 S.Ct. 1070, 87 L.Ed. 1407

Great Lakes Dredge & Dock Co.



No. 849

United States Supreme Court

May 24, 1943

Argued May 5, 6, 1943




1. In the light of its opinion, findings, and conclusions of law, the District Court's dismissal of the suit rests wholly upon its declaration that, as applied to the plaintiffs, the state statute is constitutional, and its judgment is, in effect, a declaratory judgment. P. 295.

2. Where federal courts, in the exercise of their jurisdiction to render declaratory judgments, are called on to adjudicate what are essentially equitable causes of action, they are free upon equitable grounds to grant or withhold the relief prayed, and considerations which have led federal courts of equity to refuse to enjoin the collection of state taxes, save in exceptional cases, require a like restraint in the use of the declaratory judgment procedure. P. 300.

3. It is in the public interest that federal courts of equity should exercise their discretionary power to grant or withhold relief so as to avoid needless obstruction of the domestic policy of the States, and

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when asked to enjoin an unconstitutional state tax, it is their duty to withhold relief when state law with the right of appeal to this Court affords adequate protection. P. 300.

4. In a suit in the federal district court against a state officer charged with the administration and enforcement of the Louisiana Unemployment Compensation Law, brought by plaintiffs engaged in navigation and operation of vessels used in improving navigable waters of the State, and praying a declaratory judgment that the state law, as applied to them and their employees, is unconstitutional, it was the duty of the court to withhold such relief, it appearing that, under the state law, a taxpayer who pays a challenged tax to the appropriate state officer may maintain a suit for reimbursement. P. 300.

5. The Acts of August 21, 1937 and August 30, 1935 do not require a result different from that here reached. P. 301.

134 F.2d 213 affirmed.

Certiorari, 318 U.S. 754, to review the affirmance of a judgment, 43 F.Supp. 981, dismissing a suit for a declaratory judgment.

STONE, J., lead opinion

MR. CHIEF JUSTICE STONE delivered the opinion of the Court.

Petitioners brought this suit in the district court against respondent, a state officer charged with the administration and enforcement of the Louisiana Unemployment Compensation Law (Act 97 of 1936, as amended by Act 164 of 1938, Act 16 of the First Extraordinary Session of 1940, and Acts 10 and 11 of 1940). The complaint alleges that petitioners have numerous classes of employees engaged in the navigation and operation of dredges and pile drivers and in the operation of quarter boats, tugs, launches,

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barges and other vessels, all used in deepening, dredging, extending, and otherwise improving channels underlying the navigable waters of the state, and that the tax or contribution to the state unemployment insurance fund which the state law would exact from each of petitioners exceeded, when the suit was brought, the sum of $3,000. The relief prayed is a declaratory judgment that the state law, as applied to petitioners and their employees, is unconstitutional and void.

After a trial, the district court held the statute applicable to petitioners and their employees and, as applied to them, a valid exercise of state power. 43 F.Supp. 981. The formal judgment ordered dismissal of the suit, but it is to be interpreted in the light of the court's opinion, findings, and conclusions of law. Metropolitan Water Co. v. Kaw Valley Drainage Dist., 223 U.S. 519, 523; Gulf Refining Co. v. United States, 269 U.S. 125, 135; Clark v. Williard, 292 U.S. 112, 118; American Propeller & Mfg. Co. v. United States, 300 U.S. 475, 479-480. So interpreted, it rests wholly on the court's declaration that the statute applied to petitioners is constitutional; it is thus, in effect, a declaratory judgment.

The Court of Appeals for the Fifth Circuit affirmed, 134 F.2d 213, holding that [63 S.Ct. 1072] the statute, in exacting from employers contributions to the state unemployment compensation fund, is a valid exercise of the state taxing power (see Steward Mach. Co. v. Davis, 301 U.S. 548; Carmichael v. Southern Coal & Coke Co., 301 U.S. 495); that the application of the Act to petitioners would not interfere with any characteristic feature of the general maritime law in its interstate and international aspects so as to fall under the ban of Southern Pac. Co. v. Jensen, 244 U.S. 205, and cases following it, and that the Federal Social Security Act, 26 U.S.C. § 1607(c)(4), by exempting from its operation officers and crews of vessels, has not "preempted the

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field" or otherwise precluded the state from applying its law with respect to the employees in question.

Because of the public importance of the questions decided, we granted certiorari, 318 U.S. 754, and set the case for argument with Standard Dredging Corp. v. Murphy and International Elevating Co. v. Murphy, post, p. 306, which are here on appeal. In our order granting the writ, we requested counsel

to discuss in their briefs and on oral argument the question whether the declaratory judgment procedure can be appropriately used in this case where the complaint seeks a judgment against a state officer to prevent enforcement of a state statute.

The state act, as the court below held, exacts of employers payments into the state unemployment insurance fund, in the nature of an excise tax upon the exercise of the right or privilege of employing individuals and measured by a percentage of the wages paid. See Carmichael v. Southern Coal & Coke Co., supra. Petitioners have challenged the state's right to collect the tax, and have interposed, as a barrier to the collection, the present suit in the federal court for a declaratory judgment. The district court, as we have indicated, has in substance given a declaratory judgment, which the Circuit Court of Appeals has sustained. Save for that purpose, those courts had no occasion to entertain the suit or pronounce any judgment in it. Neither court nor any of the parties has questioned the sufficiency of the pleadings to present a case for a declaratory judgment. Without raising that issue here, we pass at once to the question, submitted to counsel, whether the declaratory judgment procedure may be appropriately resorted to in the circumstances of this case.

In answering it, the nature of the...

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