Pierce Butler

“ A state asking leave to sue another to prevent the enforcement of laws must allege, in the complaint offered for filing, facts that are clearly sufficient to call for a decree in its favor. Our decisions definitely establish that not every matter of sufficient moment to warrant resort to equity by one person against another would justify an interference by this court with the action of a state. ”

“ And enforcement of the statutes in question will prevent Alabama from selling in defendant states potatoes produced by the labor of its convicts.
Alabama's investment in the cotton mills and shirt factory exceeds $300,000 and will be valueless as a result of its inability to find an employer for its convict labor and a market for its prison-made goods. The cost of maintaining unemployed convicts will be about $550,000 annually. Without employment convicts cannot be treated appropriately for their rehabilitation and the promotion of the good order and welfare of the state. ”

“ The burden upon the plaintiff state fully and clearly to establish all essential elements of its case is greater than that generally required to be borne by one seeking an injunction in a suit between private parties. ”