Learn about the case — historical background and documents
The Federal Courts and Their Jurisdiction
U.S. Circuit Court for the Northern District of Illinois
The U.S. Circuit Court for the Northern District of Illinois issued the injunction to prohibit Debs and the union officers from any strike activity that might restrain interstate commerce or the transportation of the mails. The Sherman Anti-Trust Act of 1890 specifically granted the U.S. circuit courts authority “to prevent and restrain” any combination or conspiracy intended to restrain trade among the states. The Act also instructed U.S. attorneys to institute proceedings in equity to restrain any violations of the act, but Debs’ attorneys challenged the application of this act to labor unions.
The U.S. circuit courts, which were established by the Judiciary Act of 1789, had jurisdiction over federal crimes, over suits between citizens from different states, and over civil suits in which the United States was a party. For the first century of the federal government, the U.S. circuit courts were the most important trial courts in the federal system; they also exercised jurisdiction over some appeals from the district courts until 1891, when Congress established the U.S. circuit courts of appeal. From 1891 until they were abolished in 1911, the U.S. circuit courts were exclusively trial courts. A circuit judge, a Supreme Court justice assigned to the circuit, any district court judge in the circuit, or some combination of two of those judges, could preside in the circuit courts.
The Sherman Anti-Trust Act authorized the U.S. circuit courts to issue injunctions against combinations or conspiracies that obstructed interstate commerce. U.S. Circuit Court Judge William A. Woods was the presiding judge sitting with U.S. District Court Judge Peter S. Grosscup when the government sought its injunction against Eugene V. Debs and the other officers of the American Railway Union. William Seaman, a district judge in the Eastern District of Wisconsin, presided in the circuit court in July 1894 and ordered Debs and the other officers held in custody for contempt of the injunction. Woods heard arguments on the contempt order and upheld the order in December 1894.
U.S. District Court for the Northern District of Illinois
Debs and his fellow officers of the American Railway Union were indicted on charges of criminal conspiracy by a grand jury in the U.S. District Court for the Northern District of Illinois. District Judge Peter S. Grosscup presided over the trial in January 1895 and dismissed the jury on February 8, 1895, after one of the jurors became too ill to serve. Grosscup’s order allowed prosecutors to retry the case, but a year later the U.S. attorney entered a nolle prosequi order, formally announcing no further intention to prosecute.
The U.S. district courts were established by the Congress in the Judiciary Act of 1789 and serve as trial courts in each of the federal judicial districts. The U.S. District Court for the Northern District of Illinois was established in 1855, when Congress divided Illinois into two judicial districts. The U.S. attorney’s office in the Northern District of Illinois initiated a criminal conspiracy prosecution under the authority of section 1 of the Sherman Anti-Trust Act of 1890, which provided criminal penalties for conspiracy in restraint of trade or commerce between the states. The district courts shared criminal jurisdiction with the circuit courts, except in capital cases, which were the exclusive jurisdiction of the circuit courts.
Supreme Court of the United States
After U.S. Circuit Court Judge William A. Woods upheld the injunction and subsequent contempt citation, lawyers for Eugene V. Debs and the American Railway Union officers petitioned the Supreme Court of the United States for a writ of error and a writ of habeas corpus. The Supreme Court accepted the petition for a writ of habeas corpus and heard arguments on the decision of the circuit court to jail the union officers for alleged violation of the injunction. The Judiciary Act of 1789 gave the Supreme Court authority to hear habeas petitions, and later decisions of the Supreme Court limited these petitions to appeals of decisions by lower federal courts. Justice David J. Brewer, who had been a lawyer and judge in Kansas before being appointed to the Supreme Court, wrote the unanimous decision in In re Debs, in which the Court upheld the contempt citation and affirmed the authority of the federal courts to issue injunctions to protect interstate commerce and the transportation of the mails and to protect the general welfare.
Article III of the Constitution established the Supreme Court and granted the Court limited original jurisdiction. The Judiciary Act of 1789 granted the Supreme Court appellate jurisdiction over cases originating in the U.S. trial courts and over appeals of state supreme court decisions relating to questions of federal law and constitutionality. An act of 1891 established U.S. courts of appeals and granted the Supreme Court greater discretion to select cases it would hear.
At the time of the Debs case, Melville W. Fuller was the Chief Justice of the United States. Since 1869, the Supreme Court has been authorized to have nine justices.
The Debs Case: Labor, Capital, and the Federal Courts of the 1890s