In response to a lawsuit from shareholders of railroad companies challenging the constitutionality of a Minnesota law lowering railroad rates, a federal court issued an injunction against the law’s enforcement. Minnesota’s attorney general, Edward Young, ignored the injunction and attempted to enforce the law in a state court proceeding. Jailed for contempt of court, he sought a writ of habeas corpus from the Supreme Court. In Ex parte Young, the Court denied the writ, holding that when a state official attempted to enforce an unconstitutional statute, that official was deemed to be acting in their personal, rather than official, capacity, and was therefore not protected by the Eleventh Amendment’s grant to the states of sovereign immunity. The decision was highly controversial; many viewed it as an unwarranted intrusion upon the concept of sovereign immunity, while others felt it was a necessary aspect of the federal judiciary’s ability to declare state laws unconstitutional.

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