ledge protested in his dissent that this provision of the act
conferred jurisdiction on the district courts from which essential
elements of the judicial power had been abstracted,[623] Chief Justice
Stone declared for the majority that the provision presented no novel
constitutional issue.

LEGISLATIVE CONTROL OVER WRITS

The authority of Congress to regulate the jurisdiction of the lower
federal courts includes that of controlling the power of the courts to
issue writs in cases where they have jurisdiction and to regulate other
ancillary powers generally.[624] Among some of the more notable
restrictions in this regard are the limitations on the power of courts
to issue injunctions, particularly in the field of taxation and labor
disputes. By the act of March 2, 1867,[625] Congress provided that "no
suit for the purpose of restraining the assessment or collection of any
tax shall be maintained in any court." There have never been any
constitutional doubts concerning this provision, which was strictly
applied for many years[626] until 1916 when the Supreme Court began to
make exceptions[627] which in the later cases[628] made the provision so
inefficacious that by October, 1935, more than 1600 suits had been filed
to restrain the collection of processing taxes under the Agricultural
Adjustment Act.[629] None of these cases, however, raises any issue
other than that of statutory interpretation, and since 1936 the Court
has interpreted the exceptions to the statute somewhat more
strictly.[630]

Injunctions in Labor Disputes; the Norris-LaGuardia Act

The Norris-LaGuardia Act of 1932[631] is significant for its
restrictions on the powers of the federal courts to issue injunctions in
labor disputes in the form of requirements for hearings followed by
findings that unlawful acts are threatened and will be committed unless
restrained, or if already committed will be continued; that substantial
injury to the property of complainants will ensue; that as to the relief
granted greater injury will be inflicted upon complainants by denying
relief than will be inflicted on defendants by granting it; that the
complainants have no adequate remedy at law; and, finally, that the
public officials charged with the protection of complainants' property
are either unable or unwilling to do so. This act has been scrupulously
applied by the Supreme Court, which has implicitly sustained its
constitutionality by construing its restrictio