Cline v. Frink Dairy Co.

Headnotes

1. Remedies — Injunctions Against Criminal Proceedings Although a court of equity generally lacks jurisdiction to restrain criminal proceedings, an exception exists where the prevention of prosecutions under an alleged unconstitutional enactment is essential to the safeguarding of property rights, and where the circumstances are exceptional and the danger of irreparable loss is both great and immediate. 274 U.S. at 451
2. Remedies — Injunctions Against Pending State Criminal Proceedings A federal court may not enjoin proceedings that were already pending in a state criminal court at the time the federal suit was begun; an injunction restraining such pending prosecutions is too broad and must be modified. 274 U.S. at 452
3. Constitutional Law — Due Process A penal statute violates due process if it either forbids or requires the doing of an act in terms so vague that persons of common intelligence must necessarily guess at its meaning and differ as to its application; the terms of the statute must be sufficiently explicit to inform those subject to it what conduct will render them liable to its penalties. 274 U.S. at 457 (quoting Connally v. General Construction Co., 269 U.S. 385, 391)
4. Constitutional Law — Due Process The Due Process Clause of the Fourteenth Amendment imposes upon the States the obligation to frame their criminal statutes so that those to whom they are addressed may know what standard of conduct is intended to be required. 274 U.S. at 458
5. Antitrust & Competition Law — Certainty of Criminal Standards A state antitrust statute that denounces conspiracies and combinations in restraint of trade but excepts agreements whose object is to conduct operations at a reasonable profit is void for uncertainty, because it leaves the whole statute without a fixed standard of guilt: the line between lawfulness and criminality is made to depend upon what commodities require trust methods to yield a reasonable profit, what would generally be a reasonable profit in such a business, and what would be a reasonable profit for a particular defendant, questions that the statute submits to the jury to resolve as a legislative rather than a judicial matter. 274 U.S. at 453–458
6. Constitutional Law — Ascertainable Standard of Guilt A statute is not unconstitutionally uncertain merely because its definition contains an element of degree as to which estimates might differ, where it employs words or phrases having a well-settled common law meaning or a technical or special meaning well enough known to enable those within its reach to apply them correctly. 274 U.S. at 459–460 (quoting Connally v. General Construction Co., 269 U.S. 385, 391)
7. Antitrust & Competition Law — Reasonableness of Prices as a Criminal Standard The distinction between legal and illegal conduct in business relations should not, absent express legislation, be made to depend on so uncertain a test as whether prices are reasonable, because agreements fixing prices are unlawful restraints in themselves and the reasonableness of a fixed price cannot be determined without a complete survey of the economic organization. 274 U.S. at 461 (quoting United States v. Trenton Potteries Co., 273 U.S. 392)
8. Constitutional Law — Due Process That courts must investigate and decide certain questions, such as what constitutes a reasonable profit, in civil actions does not justify holding a person criminally liable in advance for failing to decide such a question rightly; a legislature must fix the standard of conduct more simply and more definitely before one can be required to conform to it or a jury can act upon it. 274 U.S. at 461–463