ty jurisdiction of the federal
courts is to be found in section 16 of the Judiciary Act of 1789, which
provided that no equity suit should be maintained where there was a full
and adequate remedy at law. Although this provision did no more than
declare a pre-existing rule long applied in chancery courts,[62] it did
assert the power of Congress to regulate the equity powers of the
federal courts. The act of March 2, 1793,[63] prohibited the issuance of
any injunction by any court of the United States to stay proceedings in
State courts except where such injunctions may be authorized by any law
relating to bankruptcy proceedings. In subsequent statutes Congress has
prohibited the issuance of injunctions in the federal courts to restrain
the collection of taxes;[64] provided for a three-judge court, as a
prerequisite to the issuance of injunctions to restrain the enforcement
of State statutes for unconstitutionality,[65] for enjoining federal
statutes for unconstitutionality,[66] and for enjoining orders of the
Interstate Commerce Commission;[67] limited the power to issue
injunctions restraining rate orders of State public utility
commissions,[68] and the use of injunctions in labor disputes;[69] and
placed a very rigid restriction of the power to enjoin orders of the
administrator under the Emergency Price Control Act.[70]

All of these restrictions have been sustained by the Supreme Court as
constitutional and applied with varying degrees of thoroughness. The
Court has made exceptions to the application of the prohibition against
the stay of proceedings in State courts,[71] but has on the whole
adhered to the statute. The exceptions raise no constitutional issues,
and the later tendency is to contract the scope of the exceptions.[72]

In Duplex Printing Company _v._ Deering,[73] the Supreme Court placed a
narrow construction upon the labor provisions of the Clayton Act and
thereby contributed in part to the more extensive restriction by
Congress of the use of injunctions in labor disputes in the
Norris-LaGuardia Act of 1932 which has not only been declared
constitutional,[74] but has been applied liberally,[75] and in such a
manner as to repudiate the notion of an inherent power to issue
injunctions contrary to statutory provisions.

Injunctions Under the Emergency Price Control Act of 1942

Lockerty _v._ Phillips[76] justifies the same conclusion. Here the
validity of the special appeals procedure of the Emergency