Younger v. Harris

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Younger v. Harris

Argued April 1, 1969
Reargued April 29, 1970
Reargued November 16, 1970
Decided February 23, 1971


Full case name:	Evelle J. Younger, District Attorney of Los Angeles County v. John Harris, Jr., Jim Dan, Diane Hirsch, and Farrel Broslawsky

Citations:	401 U.S. 37; 91 S. Ct. 746; 27 L. Ed. 2d 669; 1971 U.S. LEXIS 136

Prior history:	Judgment for plaintiffs, 281 F.Supp. 507 (C.D. Cal. 1968)

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.

Court membership

Chief Justice: Warren E. Burger
Associate Justices: Hugo Black, William O. Douglas, John Marshall Harlan II, William J. Brennan, Potter Stewart, Byron White, Thurgood Marshall, Harry Blackmun

Case opinions

Majority by: Black
Joined by: Burger, Harlan, Stewart, Blackmun
Concurrence by: Stewart
Joined by: Harlan
Concurrence by: Brennan
Joined by: White, Marshall
Dissent by: Douglas

Laws applied

28 U.S.C. § 2283

Younger v. Harris, 401 U.S. 37 (1971)^[1], 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.

[edit] Facts

A California statute prohibited advocating communism. 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; others asserted that their advocacy of socialism and teaching of Marxism would be chilled unless the District Court enjoined the DA's prosecution of Harris.

[edit] 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.