Steffel v. Thompson

415 U.S. 452 (1974)

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Steffel v. Thompson

United States Supreme Court
415 U.S. 452 (1974)

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Facts

Richard Steffel (plaintiff) was among a group distributing antiwar handbills outside a Georgia shopping center (defendant). The police warned that continued distribution would result in arrest for criminal trespass, and the group left. Two days later, Steffel and Sandra Becker (plaintiff) went to the same shopping center to distribute handbills, prompting the police to issue the same warning. Steffel left, but Becker persisted, was arrested, and faced prosecution in state court. Steffel and Becker sued the shopping center’s owner and various Georgia officials in federal court, seeking (1) a declaratory judgment that Georgia’s criminal-trespass statute was being applied in a manner that violated the First Amendment and (2) an injunction preventing the statute’s enforcement. In the lawsuit, the parties stipulated that Steffel would be arrested if he tried to distribute handbills at the shopping center again. The district court declined to issue any relief and dismissed the lawsuit. Only Steffel appealed, specifically contesting only the denial of his request for a declaratory judgment. The Fifth Circuit affirmed, finding federal declaratory relief was appropriate only if the state’s threat to prosecute Steffel created an irreparable injury, such as if the prosecution threat was a type of bad-faith harassment, and there was no evidence of any irreparable injury. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Brennan, J.)

Concurrence (Rehnquist, J.)

Concurrence (Stewart, J.)

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