Sterling v. Constantin (SCOTUS 1932)

Summary

The Supreme Court affirmed the district court’s permanent injunction against Governor Sterling, the Adjutant General, and General Wolters, holding that the Governor lacked authority to limit oil production by military order and that such actions were subject to federal judicial review under the Fourteenth Amendment. The Court rejected the claim that martial law declarations are beyond judicial scrutiny and affirmed that the injunction was a proper equitable remedy.

Holding

Did the Governor of Texas have authority to limit oil production by military order under the state constitution and statutes?. No; the Governor lacked statutory and constitutional authority to regulate oil production by military order, and the injunction was proper.

Are federal courts empowered to enjoin state officials acting under color of state law in this context?. Yes; under Ex parte Young the federal courts have jurisdiction to enjoin state officials who exceed their lawful authority.

Is a declaration of martial law by a governor subject to judicial review?. Yes; martial law declarations are not beyond judicial scrutiny and may be reviewed for constitutional compliance.

Did the Governor’s actions violate the Due Process Clause of the Fourteenth Amendment?. Yes; the Governor’s orders deprived the plaintiffs of their property rights without due process of law.

Did the Governor’s actions violate the Equal Protection Clause of the Fourteenth Amendment?. Yes; the discriminatory application of military orders to restrict oil production infringed equal protection guarantees.

Summary

Holding

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