Younger v. Harris
Encyclopedia
Younger v. Harris, 401 U.S. 37
(1971), was a case in which the United States Supreme Court held that United States federal courts
were required to abstain
from hearing any civil rights
tort
claims brought by a person who is currently being prosecuted for a matter arising from that claim.
statute prohibited advocating "unlawful acts of force or violence [to] effect political change." The defendant
, Harris, was charged with violating the statute, and he sued under 42 U.S.C. § 1983 to get an injunction preventing District Attorney Evelle J. Younger
from enforcing the law on the grounds that it violated the free speech guarantee.
There are three exceptions to Younger abstention:
. The doctrine applies even where the state does not bring an action until after the person has filed a lawsuit in federal court, provided that the federal court has not yet taken any action on the suit. Moreover, the principle of abstention applies to some state administrative proceedings.
In regard to the exceptions which the Younger Court articulated, later decisions make it clear that these are highly difficult to meet.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1971), was a case in which the United States Supreme Court held that United States federal courts
United States federal courts
The United States federal courts make up the judiciary branch of federal government of the United States organized under the United States Constitution and laws of the federal government.-Categories:...
were required to abstain
Abstention doctrine
An abstention doctrine is any of several doctrines that a court of law in the United States of America might apply to refuse to hear a case, when hearing the case would potentially intrude upon the powers of another court...
from hearing any civil rights
Civil rights
Civil and political rights are a class of rights that protect individuals' freedom from unwarranted infringement by governments and private organizations, and ensure one's ability to participate in the civil and political life of the state without discrimination or repression.Civil rights include...
tort
Tort
A tort, in common law jurisdictions, is a wrong that involves a breach of a civil duty owed to someone else. It is differentiated from a crime, which involves a breach of a duty owed to society in general...
claims brought by a person who is currently being prosecuted for a matter arising from that claim.
Facts
A CaliforniaCalifornia
California is a state located on the West Coast of the United States. It is by far the most populous U.S. state, and the third-largest by land area...
statute prohibited advocating "unlawful acts of force or violence [to] effect political change." The defendant
Defendant
A defendant or defender is any party who is required to answer the complaint of a plaintiff or pursuer in a civil lawsuit before a court, or any party who has been formally charged or accused of violating a criminal statute...
, Harris, was charged with violating the statute, and he sued under 42 U.S.C. § 1983 to get an injunction preventing District Attorney Evelle J. Younger
Evelle J. Younger
Evelle Jansen Younger was an American politician. He was California Attorney General from 1971 to 1979. Prior to that, he was Los Angeles County District Attorney from 1964 to 1971. In 1978, he ran for Governor of California, but lost to incumbent Jerry Brown. Younger was a member of the...
from enforcing the law on the grounds that it violated the free speech guarantee.
Decision and precedent
A federal court may not hear the case until the person is convicted or found not guilty of the crime unless the defendant will suffer an irreparable injury that is "both great and immediate." Merely having to endure a criminal prosecution is no such irreparable harm.There are three exceptions to Younger abstention:
- Where the prosecution is in bad faith (i.e. the state knows the person to be innocent)—as applied in Dombrowski v. PfisterDombrowski v. PfisterDombrowski v. Pfister was a landmark Supreme Court case brought forth by Dr. James Dombrowski along with William Kunstler, founder of the Center for Constitutional Rights, against the governor of Louisiana, law enforcement officers, and the chairperson of the state's Legislative Joint Committee...
; or - Where the prosecution is part of some pattern of harassment against an individual; or
- Where the law being enforced is utterly and irredeemably unconstitutional (i.e., if the state were to pass a law making it a crime to say anything negative about its governor under any circumstances).
Status as precedent
The doctrine was later extended to situations where the state is seeking to execute a civil fine against someone, or has jailed a person for contempt of courtContempt of court
Contempt of court is a court order which, in the context of a court trial or hearing, declares a person or organization to have disobeyed or been disrespectful of the court's authority...
. The doctrine applies even where the state does not bring an action until after the person has filed a lawsuit in federal court, provided that the federal court has not yet taken any action on the suit. Moreover, the principle of abstention applies to some state administrative proceedings.
In regard to the exceptions which the Younger Court articulated, later decisions make it clear that these are highly difficult to meet.
- Bad faith prosecution: in no case since Younger was decided has the Supreme Court found there to exist bad faith prosecution sufficient to justify a federal court injunction against state court proceedings. The Court has specifically declined to find bad faith prosecution even in circumstances where repeated prosecutions had occurred. As commentator Erwin ChemerinskyErwin ChemerinskyErwin Chemerinsky is an American lawyer and law professor. He is a prominent scholar in United States constitutional law and federal civil procedure...
states, the bad-faith prosecution exception seems narrowly limited to facts like those in Dombrowski. Other scholars have even asserted that the possible range of cases which would fit the Dombrowski model and allow an exception to the no-injunction rule is so limited as to be an "empty universe." - Patently unconstitutional law: in no case since Younger was decided has the Supreme court found there to exist a patently unconstitutional law sufficient to justify a federal court injunction against state court proceedings. The Court has specifically declined to find such patent unconstitutionality in at least one case (Trainor v. Hernandez)
- Inadequate state forum: the Supreme Court has found the state forum in question to be inadequate on a small number of occasions.
See also
- Abstention doctrineAbstention doctrineAn abstention doctrine is any of several doctrines that a court of law in the United States of America might apply to refuse to hear a case, when hearing the case would potentially intrude upon the powers of another court...
- Anti-Injunction ActAnti-Injunction ActThe Anti-Injunction Act, , is a United States federal statute that prohibits any federal court from issuing an injunction against proceedings in any state court, except within three specifically defined exceptions...
- List of United States Supreme Court cases, volume 401