Samuels v. Mackell

Facts of the Case

The plaintiffs, having been indicted in a New York state court on charges of criminal anarchy, requested the United States District Court for the Southern District of New York to grant injunctive relief and a declaratory judgment to the effect that the New York criminal anarchy statutes were unconstitutional under the First and Fourteenth Amendments. The plaintiffs alleged that the state criminal proceedings would harass them and cause them to suffer irreparable injury. A three-judge District Court, dismissing the plaintiffs’ complaint, held that the New York criminal anarchy statutes were constitutional. Plaintiffs challenged the decision.

Question

Are the New York criminal anarchy laws unconstitutionally vague?

CONCLUSION

No decision. Justice Hugo L. Black, writing for the unanimous Court, affirmed the lower court. The Supreme Court held that the defendants would not suffer irreparable damages if the state trial continued. The Court also held that the district court should not have evaluated the case on the merits because of the pending statute court proceedings. Justice William O. Douglas concurred, writing that the New York laws were not obviously unconstitutional, so it was up to the state court to evaluate the matter. Justice Potter Stewart wrote a separate concurrence, emphasizing that the majority decision dealt only with the proper procedure for a federal court to follow when a criminal prosecution is pending in state court. Justice John M. Harlan joined in the concurrence. Justice William J. Brennan concurred in the result, stating that the defendants did not allege bad-faith harassment by the prosecution, so an injunction would be improper.

Case Information