Regarding SCOTUS's recent refusal to issue an injunction in Whole Women's Health v. Jackson.

in scotus •  3 years ago 

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I am at risk here of making an argument on a complex topic well outside my area of expertise, but will forge on anyway. If anyone with the relevant experience with the Federal Rules of Civil Procedures reads this and realizes I've erred, feel free to correct.

I've come to the conclusion that SCOTUS had no available options for granting meaningful relief in the WWH v. Jackson injunction request.

Because of 11th Amendment sovereign immunity (extended via "Hans v. Louisiana)", it's not possible to sue a state to nullify a law. What is possible (via "Ex Parte Young") is to sue those state officers charged with enforcing that law to prohibit them from doing so. (That bit of nuance has some important implications)

In the recent injunction request, the plaintiff's counsel listed one specific Texas judge and one specific Texas court clerk as respondents. Further, the suit listed them as representatives of their respective classes (i.e, "Texas judges" and "Texas court clerks"), but never submitted a motion to have those classes certified. (i.e., there was no counsel present that was representing "Texas judges" as a class)

The only remedy I can find that SCOTUS could have legally granted would be to have prohibited that one specific judge and that one specific court clerk from hearing SB8 suits. That would be effectively meaningless of course, because every other state judge in Texas could still hear those SB8 suits.

Am I missing something? Do the FRCP allow for some injunctive relief that I am just unfamiliar with?

I'm far from an expert, but I don't see any opportunity here for a pre-enforcement challenge to SB8. (Other than filing a motion seeking to certify Texas judges as a class, then seeking an injunction against them via Ex Parte Young)

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