Younger v. Harris

SCOTUSCase
Litigants=Younger v. Harris
ArgueDate=April 1
ArgueYear=1969
ReargueDate=April 29
ReargueYear=1970
ReargueDate2=November 16
ReargueYear2=1970
DecideDate=February 23
DecideYear=1971
FullName=Evelle J. Younger, District Attorney of Los Angeles County v. John Harris, Jr., Jim Dan, Diane Hirsch, and Farrel Broslawsky
USVol=401
USPage=37
Citation=91 S. Ct. 746; 27 L. Ed. 2d 669; 1971 U.S. LEXIS 136
Prior=Judgment for plaintiffs, 281 F.Supp. 507 (C.D. Cal. 1968)
Subsequent=
Holding=The possible unconstitutionality of a state statute is not grounds for a federal court to enjoin state court criminal proceedings brought pursuant to that statute. District Court for the Central District of California reversed and remanded.
SCOTUS=1970-1971
Majority=Black
JoinMajority=Burger, Harlan, Stewart, Blackmun
Concurrence=Stewart
JoinConcurrence=Harlan
Concurrence2=Brennan
JoinConcurrence2=White, Marshall
Dissent=Douglas
LawsApplied=UnitedStatesCode|28|2283

"Younger v. Harris", 401 U.S. 37 (1971)ref|citation, 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. For example, if an individual who was charged with drug possession believes that the search was illegal, and in violation of their Fourth Amendment rights, that person may ultimately have a cause of action to sue the state for illegally searching him.

Facts

A California 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 Younger from enforcing the law on the grounds that it violated the free speech guarantee.

Result

A federal court may not hear the case until the person is convicted 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:
*1. Where the prosecution is in bad faith (i.e. the state knows the person to be innocent); or
*2. Where the prosecution is part of some pattern of harassment against an individual; or
*3. 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).

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 court. 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.

ee also

*List of United States Supreme Court cases, volume 401

External links

*ussc|401|37|Text of the opinion on Findlaw.com