In doing so, the court created a limit on the federal injunctive power in matters of state agency internal affairs.

[1] In the United States District Court for the Eastern District of Pennsylvania, plaintiffs sued a number of Philadelphia officials in a § 1983 suit,[2] charging that the police department had engaged in a "pervasive pattern of illegal and unconstitutional mistreatment by police officers.

In discussing the latter, Justice Rehnquist (as he then was) explained that: The Supreme Court cast the case as "a heated dispute between individual citizens and certain policemen ... [that] has evolved into an attempt by the federal judiciary to resolve a 'controversy' between the entire citizenry of Philadelphia and the petitioning elected and appointed officials over what steps might, in the Court of Appeals' words, '[appear] to have the potential for prevention of future police misconduct.

'"[6] The court - "express[ing] grave doubts about the justiciability" of the case[7] - held that "the individual respondents' claim to 'real and immediate' injury rests not upon what the named petitioners might do to them in the future -- such as set a bond on the basis of race -- but upon what one of a small, unnamed minority of policemen might do to them in the future because of that unknown policeman's perception of departmental disciplinary procedures.

This hypothesis is even more attenuated than those allegations of future injury found insufficient in O'Shea[8] to warrant invocation of federal jurisdiction.