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Home Telephone & Telegraph Co. v. City of Los Angeles

United States Supreme Court

227 U.S. 278 (1913)

Relevant factsFree

Home Telephone & Telegraph Co. (plaintiff) sued Los Angeles (defendant) in federal court to enjoin an allegedly confiscatory city telephone-rate ordinance as a violation of the Fourteenth Amendment's Due Process Clause; the district court dismissed for lack of jurisdiction, reasoning that if a state official's action also violated the state constitution, it couldn't simultaneously be a "state action" violating the federal Constitution until state courts had finally resolved the matter.

IssueFree

Whether federal courts have original jurisdiction over claims that a state official, acting under state authority, violated the Fourteenth Amendment, without waiting for state court proceedings to conclude.

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