Texas Unemployment Compensation Commission v. Campbell, Wise & Wright, Inc.
The Texas Unemployment Compensation Commission appealed a temporary injunction granted without notice by the 117th District Court of Nueces County on February 10, 1938. The injunction prevented the Commission from collecting taxes, penalties, or interest under the Texas Unemployment Compensation Act from fifty-seven appellees (vegetable and fruit shippers) and from using their private records. The appellees argued the Act was unconstitutional, their employees were exempt as agricultural laborers, or independent contractors. The appellate court, referencing the 'Stephens Case,' determined that an injunction is improper when an adequate legal remedy exists. The court found that the Commission's enforcement actions would involve regular court proceedings where the appellees could present their defense, thus providing an adequate remedy at law. The court also dismissed the argument of preventing a multiplicity of suits, as the State would likely bring a single action per taxpayer. Therefore, the appellate court reversed the lower court's decision and dissolved the temporary injunction.