Steffel v. Thompson

Facts of the Case

Petitioner-Plaintiff, with others, instituted an action in the United States District Court for the Northern District of Georgia, seeking a declaratory judgment under the

Question

Does the case present an actual and active controversy?Can a federal court grant declaratory relief against the enforcement of a state statute when a criminal proceeding is pending?

CONCLUSION

Yes, yes. Justice William J. Brennan, Jr. delivered the unanimous opinion. The Court held that the case presented an actual controversy, as the Georgia statute could interfere with Steffel’s exercise of his constitutional rights even if he was not arrested. Because the United States’ involvement in Vietnam, which Steffel was protesting, was reduced, the issue of whether or not the case still presented an active controversy would be decided by the lower court on remand. The Court also held that awarding declaratory relief would not interfere with the state’s prosecution, and therefore is not precluded.Justice Potter Stewart wrote a concurring opinion and argued that plaintiffs in such constitutional cases must prove that the state’s actions represented a “genuine threat” to their constitutional liberties, which he predicts will be rare. Chief Justice Warren E. Burger joined in the concurrence.In his concurring opinion, Justice Byron R. White wrote that it would not be improper to issue declaratory or injunctive relief in state courts on issues that have already been decided by federal courts. He also argues that such measures should not be necessary because the decisions of federal courts carry more weight than precedents in state courts.Justice William H. Rehnquist wrote a concurring opinion and argued that issuing declaratory relief does not allow a plaintiff to avoid prosecution under state law. He also argued that this opinion does not provide support for the ability of federal courts to grant injunctive relief just because declarative relief was appropriate. Chief Justice Warren E. Burger joined in the concurrence.

Case Information

  • Citation: 415 US 452 (1974)
  • Argued: Nov 13, 1973
  • Decided Mar 19, 1974Granted: Feb 26, 1973