Leiter Minerals v. United States, No. 26

CourtUnited States Supreme Court
Writing for the CourtFRANKFURTER
Citation1 L.Ed.2d 267,352 U.S. 220,77 S.Ct. 287
Docket NumberNo. 26
Decision Date14 January 1957
PartiesThe LEITER MINERALS, Inc., Petitioner, v. UNITED STATES of America et al

352 U.S. 220
77 S.Ct. 287
1 L.Ed.2d 267
The LEITER MINERALS, Inc., Petitioner,

v.

UNITED STATES of America et al.

No. 26.
Argued Nov. 6 and 7, 1956.
Decided Jan. 14, 1957.

Mr. Samuel W. Plauche , Jr., Lake Charles, La., for petitioner.

Mr. Perry W. Morton, Washington, D.C., for respondent United States of America.

Page 221

Mr. Charles D. Marshall, New Orleans, La., for respondents The California Co. and Allen L. Lobrano.

Mr. Justice FRANKFURTER delivered the opinion of the Court.

This case presents for decision important questions regarding the applicability to the United States of the restrictions against stay of state court proceedings contained in 28 U.S.C. § 2283, 28 U.S.C.A. § 2283 and the propriety of the injunction decreed by the District Court and sustained by the Court of Appeals. Petitioner in 1953 had filed a petitory action in a Louisiana state court against respondent-mineral-lessees of the United States. In that action, a suit by one out of possession claiming title to, and possession of, immovables, petitioner sought to have itself declared owner of the mineral rights under land owned by the United States, and it also sought an accounting for oil and other minerals removed by respondent-lessees under their lease from the United States. Petitioner founded its claim on Louisiana Act No. 315 of 1940, La.Rev.Stat., 1950, 9:5806, which, it alleged, made 'imprescriptible' a reservation of mineral rights in a deed of December 21, 1938, to the United States by its predecessor in title.1

Page 222

Respondent-lessees filed exceptions in the state court proceedings, urging that under Louisiana law the lessor should be made a party and the lessees discharged from the suit, that this was essentially a suit against the United States, which had not consented to be sued, that the United States was an indispensable party, and that no cause of action had been stated. The state trial court found that a cause of action had been stated, and it overruled the exceptions.

At this point the United States, joining petitioner and other interested parties as defendants, brought the present

Page 223

suit in the District Court for the Eastern District of Louisiana to quiet title to the mineral rights; it also sought a preliminary injunction to restrain petitioner from prosecuting its action in the state court. The United States based its claim of ownership on the provision in the 1938 deed from petitioner's predecessor in title that the reservation of mineral rights would expire on April 1, 1945, subject to certain conditions not material to this case. The United States claimed that irreparable injury in the form of loss of royalties would result from any temporary, wrongful dispossession of its lessees by the state court proceedings. Affidavits were also submitted in support of the claim that permanent loss of wells currently producing oil would probably result from any temporary cessation of production. The petitioner moved to dismiss the United States' complaint on the ground that the state court had already assumed jurisdiction over the property in question; in the alternative, petitioner moved to stay the federal proceedings pending determination of the state court action because questions of state law were involved.

The District Court held that, since the United States was not a party to the state court suit, the title of the United States could be tried only in the federal court action and that an injunction against prosecution of the state proceedings should issue to protect its jurisdiction pending determination of the ownership of the property. 127 F.Supp. 439. The Court of Appeals affirmed, holding that the preliminary injunction was proper because 'the district court under the clear provisions of the statute, 28 U.S.C. § 1345 (28 U.S.C.A. § 1345), became vested with exclusive jurisdiction to determine the title of the United States to the mineral rights claimed by appellant.' 224 F.2d 381, 383 384. Because of the presence of important and difficult questions of federal-state relations, questions

Page 224

more difficult than the Government appears to have found them, we granted certiorari. 350 U.S. 964, 76 S.Ct. 439.

28 U.S.C. § 2283, 28 U.S.C.A. § 2283, provides:

'A court of the United States may not grant an injunction to stay proceedings in a State court except as expressly authorized by Act of Congress, or where necessary in aid of its jurisdiction, or to protect or effectuate its judgments.'

It must first be decided whether this section applies to stays sought by the United States because different answers to this question will put different aspects on other issues in the case. An analogous problem was presented in United States v. United Mine Workers, 330 U.S. 258, 67 S.Ct. 677, 91 L.Ed. 884, where the Court held that the provisions of the Norris-La Guardia Act, 47 Stat. 70, 29 U.S.C. § 101, 29 U.S.C.A. § 101, that no federal court had jurisdiction, subject to qualifications, to issue an injunction in labor disputes to prohibit certain acts, did not apply to the United States. The Norris-La Guardia Act, like 28 U.S.C. § 2283, 28 U.S.C.A. § 2283, effected, in general language, a limitation on the jurisdiction of the federal courts. Furthermore, since it was largely the diversity jurisdiction which spawned the substantive problems that the Norris-La Guardia Act removed from the federal courts, the limitations on the federal courts imposed by the Norris-La Guardia Act, like those of 28 U.S.C. § 2283, 28 U.S.C.A. § 2283, were in an area of federal-state relations calling for particular circumspection in adjudication.

In interpreting the general language of the Norris-La Guardia Act, the Court relied heavily on 'an old and wellknown rule,' albeit a rule of construction, 'that statutes which in general terms divest pre-existing rights or privileges will not be applied to the sovereign without express words to that effect.' 330 U.S. at page 272, 67 S.Ct. at page 686.

Page 225

While, strictly speaking, any 'pre-existing' rights would have to be found in the 1789—1793 pre-statute period, 2 the rationale of the rule requires not that the rights be 'pre-existing' but rather that they would exist apart from the statute. There can be no doubt, apart from the restrictions of 28 U.S.C. § 2283, 28 U.S.C.A. § 2283; of the right of the United States to enjoin state court proceedings whenever the prerequisites for relief by way of injunction be present. Treating the rule invoked in the United Mine Workers case merely as an aid to construction, it would by itself lead us to hold that the general language of 28 U.S.C. § 2283, 28 U.S.C.A. § 2283, did not apply to the United States in the absence of countervailing considerations, such as significant legislative history pointing toward its inclusion or inferences clearly to be drawn from relevant presuppositions for so including it.

In United Mine Workers, the Court did not rely entirely on the rule of construction because its reading of the Act as a whole and the legislative history supported the conclusion that the United States was not to be included. In this case, there is no legislative material to support or to gainsay the applicability of the rule of construction. There is, however, a persuasive reason why the federal court's power to stay state court proceedings might have been restricted when a private party was seeking the stay but not when the United States was seeking similar relief. The statute is designed to prevent conflict between federal and state courts. This policy is much more compelling when it is the litigation of private parties which threatens to draw the two judicial systems into conflict than when it is the United States which seeks a stay to prevent threatened irreparable injury to a

Page 226

national interest. The frustration of superior federal interests that would ensue from precluding the Federal Government from obtaining a stay of state court proceedings except under the severe restrictions of 28 U.S.C. § 2283, 28 U.S.C.A. § 2283, would be so great that we cannot reasonably impute such a purpose to Congress from the general language of 28 U.S.C. §...

To continue reading

Request your trial
214 practice notes
  • United States v. Livingston, Civ. A. No. AC-174.
    • United States
    • United States District Courts. 4th Circuit. United States District Court of South Carolina
    • November 18, 1959
    ...which to have their cause heard in the State Court, retaining jurisdiction in the meantime. See: Leiter Minerals, Inc. v. United States, 352 U.S. 220, 77 S.Ct. 287, 1 L. Ed.2d 267; City of Meridian v. Southern Bell Tel. & Tel. Co., 358 U.S. 639, 79 S.Ct. 455, 3 L.Ed.2d 562; George F. Alger ......
  • Hodgson v. Hamilton Municipal Court, No. 7954.
    • United States
    • United States District Courts. 6th Circuit. United States District Courts. 6th Circuit. Southern District of Ohio
    • July 31, 1972
    ...has ruled that injunctive suits brought by the United States are not barred by 28 U.S.C. § 2283. Leiter Minerals, Inc. v. United States, 352 U.S. 220, 77 S.Ct. 287, 1 L.Ed.2d 267 (1957); Mitchum v. Foster, 407 U.S. 225, 92 S.Ct. 2151, 32 L.Ed.2d 705 (1972). By the better view, the exception......
  • Salvati v. Dale, Civ. A. No. 73-461
    • United States
    • United States District Courts. 3th Circuit. United States District Court (Eastern District of Pennsylvania)
    • October 5, 1973
    ...should be slow to intervene where State court proceedings are so clearly the more appropriate. Leiter Minerals, Inc. v. United States, 352 U.S. 220, 77 S.Ct. 287, 1 L.Ed.2d 267 (1957). In City of Meridian v. Southern Bell Telephone Company, 358 U.S. 639, 79 S.Ct. 455, 3 L.Ed.2d 562 (1959), ......
  • Langley v. Ryder, Civ. A. No. 85-0030.
    • United States
    • U.S. District Court — Western District of Louisiana
    • March 15, 1985
    ...interest is well-established. NLRB v. Nash-Finch Co., 404 U.S. 138, 92 S.Ct. 373, 30 L.Ed.2d 328 (1971); Leiter Minerals v. United States, 352 U.S. 220, 77 S.Ct. 287, 1 L.Ed.2d 267 (1957). Thus, these cases already had a sound basis for entertaining the request for injunctive relief without......
  • Request a trial to view additional results
213 cases
  • United States v. Livingston, Civ. A. No. AC-174.
    • United States
    • United States District Courts. 4th Circuit. United States District Court of South Carolina
    • November 18, 1959
    ...which to have their cause heard in the State Court, retaining jurisdiction in the meantime. See: Leiter Minerals, Inc. v. United States, 352 U.S. 220, 77 S.Ct. 287, 1 L. Ed.2d 267; City of Meridian v. Southern Bell Tel. & Tel. Co., 358 U.S. 639, 79 S.Ct. 455, 3 L.Ed.2d 562; George F. Alger ......
  • Hodgson v. Hamilton Municipal Court, No. 7954.
    • United States
    • United States District Courts. 6th Circuit. United States District Courts. 6th Circuit. Southern District of Ohio
    • July 31, 1972
    ...has ruled that injunctive suits brought by the United States are not barred by 28 U.S.C. § 2283. Leiter Minerals, Inc. v. United States, 352 U.S. 220, 77 S.Ct. 287, 1 L.Ed.2d 267 (1957); Mitchum v. Foster, 407 U.S. 225, 92 S.Ct. 2151, 32 L.Ed.2d 705 (1972). By the better view, the exception......
  • Salvati v. Dale, Civ. A. No. 73-461
    • United States
    • United States District Courts. 3th Circuit. United States District Court (Eastern District of Pennsylvania)
    • October 5, 1973
    ...should be slow to intervene where State court proceedings are so clearly the more appropriate. Leiter Minerals, Inc. v. United States, 352 U.S. 220, 77 S.Ct. 287, 1 L.Ed.2d 267 (1957). In City of Meridian v. Southern Bell Telephone Company, 358 U.S. 639, 79 S.Ct. 455, 3 L.Ed.2d 562 (1959), ......
  • Langley v. Ryder, Civ. A. No. 85-0030.
    • United States
    • U.S. District Court — Western District of Louisiana
    • March 15, 1985
    ...interest is well-established. NLRB v. Nash-Finch Co., 404 U.S. 138, 92 S.Ct. 373, 30 L.Ed.2d 328 (1971); Leiter Minerals v. United States, 352 U.S. 220, 77 S.Ct. 287, 1 L.Ed.2d 267 (1957). Thus, these cases already had a sound basis for entertaining the request for injunctive relief without......
  • Request a trial to view additional results
1 books & journal articles
  • EQUITY AND THE SOVEREIGN.
    • United States
    • Notre Dame Law Review Vol. 97 Nbr. 5, May 2022
    • May 1, 2022
    ...common law to preempt a state law laches defense in a suit brought by the United States). (62) Leiter Mins., Inc. v. United States, 352 U.S. 220, 225-26 (1957) (holding that the Anti-Injunction Act does not bar the United States from seeking a stay of state court proceedings); United States......

VLEX uses login cookies to provide you with a better browsing experience. If you click on 'Accept' or continue browsing this site we consider that you accept our cookie policy. ACCEPT