Supreme Court of the United States
Donovan v. City of Dallas
June 8, 1964377 U.S. 408
Summary
The Court held that a state court lacks authority to enjoin a litigant from pursuing an in‑personam action in federal court, and therefore vacated the Texas Court of Civil Appeals' contempt judgment based on an invalid injunction, reversing the Texas Supreme Court and remanding for further proceedings. Justice Harlan’s dissent argued that the state court could enjoin vexatious federal litigation and would have affirmed the injunction and contempt findings.
Holding
- Whether a state court may enjoin a person from prosecuting an in‑personam action in federal court. State courts have no power to enjoin litigants from pursuing in‑personam actions in federal courts.
- Whether the contempt convictions based on the state court’s injunction are valid. The contempt judgments are vacated because they were predicated on an invalid injunction.
Docket 264
Cited authorities
- 28 U.S.C. § 1651
- 36 Stat. 291
- 45 U.S.C. § 56