Supreme Court of the United States

Aircraft & Diesel Equipment Corp. v. Hirsch

June 16, 1947331 U.S. 752

Summary

The Court affirmed dismissal of a subcontractor’s suit seeking declaratory and injunctive relief against enforcement of the Renegotiation Acts while its Tax Court redetermination proceedings remained pending. Congress required completion, not merely initiation, of that administrative process, and raising constitutional objections did not excuse exhaustion on this record. The subcontractor also had an adequate legal remedy through suits against its customers, supported by the Government’s statutory indemnity; its allegations of irreparable injury and multiplicity of suits did not justify equitable intervention. The Court reserved the constitutionality of the Acts, the ultimate finality of Tax Court decisions, and whether this action was effectively an unconsented suit against the United States. Justice Jackson concurred in the result, and Justice Douglas dissented; neither supplied a separate opinion in the text.

Holding

  • Whether pending Tax Court proceedings had to be completed before judicial intervention in this action.. The subcontractor was required to await completion of the prescribed Tax Court proceedings; initiating those proceedings and raising constitutional questions did not excuse exhaustion under the circumstances presented.
  • Whether the subcontractor established grounds for equitable relief despite its contractual remedies against its customers.. The available suits against customers supplied an adequate remedy at law, and the allegations of multiplicity of suits and irreparable injury were insufficient to sustain equitable intervention.

Docket 95

Cited authorities

  • 50 Stat. 751
  • 28 U.S.C. § 380
  • 56 Stat. 226
  • 56 Stat. 798
  • 57 Stat. 347
  • 57 Stat. 564
  • 58 Stat. 21
  • 59 Stat. 294

Cited by

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