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Home Telephone & Telegraph Co. v. City of Los Angeles
United States Supreme Court
227 U.S. 278 (1913)
Home Telephone & Telegraph Co. (HT&T) (plaintiff) was a California corporation that provided telephone services in the city of Los Angeles (defendant). HT&T sued the city and city officials to enjoin enforcement of a city ordinance establishing telephone rates that HT&T alleged were unreasonably low and in violation of the Due Process Clause of the Fourteenth Amendment. HT&T filed the complaint in the United States District Court for the Southern District of California, which dismissed the complaint for lack of federal court jurisdiction. The district court reasoned that a suit alleging that violation of the United States Constitution also implicitly alleged a violation of the state constitution. If a state official violates the state constitution, then that act cannot be said to be a state action in violation of the United States Constitution. The district court reasoned, therefore, that federal courts did not have jurisdiction until after final disposition of the case by the state court. HT&T took a direct appeal to the United States Supreme Court.
Rule of Law
Holding and Reasoning (White, J.)
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