Douglas v. City of Jeannette

Douglas v. City of Jeannette, 319 U.S. 157 (1943), was a case in which the Supreme Court of the United States held it does not restrain criminal prosecutions made in good faith unless there would be some "irreparable injury."[1] This case is one of four cases collectively known as the "Jehovah's Witnesses Cases", because the Supreme Court handed down rulings on these four cases related to the Jehovah's Witnesses on the same day (May 3, 1943). Although the Supreme Court ruled against the Jehovah's Witnesses in this case, it ruled in favor of them in the other three cases and those represent landmark decisions in the area of First Amendment constitutional law.

Douglas v. City of Jeannette
Argued March 10–11, 1943
Decided May 3, 1943
Full case nameDouglas v. City of Jeannette
Citations319 U.S. 157 (more)
63 S. Ct. 877; 87 L. Ed. 1324; 1943 U.S. LEXIS 712
Case history
Prior39 F. Supp. 32 (W.D. Pa. 1941); 130 F.2d 652 (3d Cir. 1942)
Holding
The ordinance as applied is held to be constitutional.
Court membership
Chief Justice
Harlan F. Stone
Associate Justices
Owen Roberts · Hugo Black
Stanley F. Reed · Felix Frankfurter
William O. Douglas · Frank Murphy
Robert H. Jackson · Wiley B. Rutledge
Case opinions
MajorityStone
ConcurrenceJackson

Facts of the case

The plaintiff in this matter was Robert L. Douglas, a Jehovah's Witness who filed suit against the Pittsburgh suburb of Jeannette, Pennsylvania in 1939. Douglas sought to enjoin against the enforcement of ordinances that prohibited him and other colleagues from distributing religious materials door-to-door without a permit.

Decision of the Court

Chief Justice Stone delivered the opinion of the Court denying equity relief on the grounds that the Court had no jurisdiction in the matter since no irreparable injury occurred, and that it was necessary to presume good faith by the municipality in reassessing the enforcement of statutes that had been declared unconstitutional. Justice Jackson's concurring opinion, appended to the majority opinion, also touched on the First Amendment issues raised in the case.

References

  1. Douglas v. City of Jeannette, 319 U.S. 157 (1943).


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