Petitioners brought this suit in the district court against respondent, a state officer charged with the administration and enforcement of the Louisiana Unemployment Compensation Law (Act 97 of 1936, as amended by Act 164 of 1938, Act 16 of the First Extraordinary Session of 1940, and Acts 10 and 11 of 1940). The complaint alleges that petitioners have numerous classes of employees engaged in the navigation and operation of dredges and pile drivers and in the operation of quarter boats, tugs, launches, barges and other vessels, all used in deepening, dredging, extending and otherwise improving channels underlying the navigable waters of the state' and that the tax or contribution to the state unemployment insurance fund which the state law would exact from each of petitioners exceeded, when the suit was brought, the sum of $3,000. The relief prayed is a declaratory judgment that the state law as applied to petitioners and their employees is unconstitutional and void.
After a trial the district court held the statute applicable to petitioners and their employees and, as applied to them, a valid exercise of state power. 43 F.Supp. 981. The formal judgment ordered dismissal of the suit, but it is to be interpreted in the light of the court's opinion, findings, and conclusions of law. Metropolitan Water Co. v. Kaw Valley Drainage Dist., 223 U.S. 519, 523, 32 S.Ct. 246, 247, 56 L.Ed. 533; Gulf Refining Co. v. United States, 269 U.S. 125, 135, 46 S.Ct. 52, 53, 70 L.Ed. 195; Clark v. Williard, 292 U.S. 112, 118, 54 S.Ct. 615, 617, 78 L.Ed. 1160; American Propeller & Mfg. Co. v. United States, 300 U.S. 475, 479, 480, 57 S.Ct. 521, 523, 81 L.Ed. 751. So interpreted it rests wholly on the court's declaration that the statute applied to petitioners is constitutional; it is thus in effect a declaratory judgment.
The Court of Appeals for the Fifth Circuit affirmed, 134 F.2d 213, holding that the statute, in exacting from employers contributions to the state unemployment compensation fund, is a valid exercise of the state taxing power (see Steward Mach. Co. v. Davis, 301 U.S. 548, 57 S.Ct. 883, 81 L.Ed. 1279, 109 A.L.R. 1293; Carmichael v. Southern Coal & Coke Co., 301 U.S. 495, 57 S.Ct. 868, 81 L.Ed. 1245, 109 A.L.R. 1327); that the application of the Act to petitioners would not interfere with any characteristic feature of the general maritime law in its interstate and international aspects so as to fall under the ban of Southern Pac. Co. v. Jensen, 244 U.S. 205, 37 S.Ct. 524, 61 L.Ed. 1086, L.R.A.1918C, 451, Ann.Cas.1917E, 900, and cases following it; and that the Federal Social Security Act, 26 U.S.C. § 1607(c)(4), 26 U.S.C.A. Int.Rev.Code, § 1607(c)(4), by exempting from its operation officers and crews of vessels, has not 'preempted the field' or otherwise precluded the state from applying its law with respect to the employees in question.
Because of the public importance of the questions decided, we granted certiorari, 318 U.S. 754, 63 S.Ct. 860, 87 L.Ed. --, and set the case for argument with No. 722, Standard Dredging Corporation v. Murphy, and No. 723, International Elevating Co. v. Murphy, 319 U.S. 306, 63 S.Ct. 1067, 87 L.Ed. --, which are here on appeal. In our order granting the writ, we requested counsel 'to discuss in their briefs and on oral argument the question whether the declaratory judgment procedure can be appropriately used in this case where the complaint seeks a judgment against a state officer to prevent enforcement of a state statute'.
The state act, as the court below held, exacts of employers payments into the state unemployment insurance fund, in the nature of an excise tax upon the exercise of the right or privilege of employing individuals and measured by a percentage of the wages paid. See Carmichael v. Southern Coal & Coke Co., supra. Petitioners have challenged the state's right to collect the tax, and have interposed, as a barrier to the collection, the present suit in the federal court for a declaratory judgment. The district court, as we have indicated, has in substance given a declaratory judgment, which the Circuit Court of Appeals has sustained. Save for that purpose those courts had no occasion to entertain the suit, or pronounce any judgment in it. Neither court, nor any of the parties, has questioned the sufficiency of the pleadings to present a case for a declaratory judgment. Without raising that issue here we pass at once to the question, submitted to counsel, whether the declaratory judgment procedure may be appropriately resorted to in the circumstances of this case.