"[W]hen a Federal court is properly appealed to in a case over which it has by law jurisdiction, it is its duty to take such jurisdiction." Willcox v. Consol. Gas Co. of N.Y., 212 U.S. 19, 40 (1909); see also Cohens v. State of Virginia, 19 U.S. 264, 404 (1821) (stating that federal courts "have no more right to decline the exercise of jurisdiction which is given, than to usurp that which is not given"). As a "general rule," this longstanding principle—that federal courts are obliged to hear and decide cases within the scope of their jurisdiction—is unimpeded by parallel state proceedings involving the same or similar subject matter. Sprint, 134 S. Ct. at 588 (citing Colo. River Water Conservation Dist. v. United States, 424 U.S. 800, 817 (1976)). This rule, however, is not absolute. The Supreme Court has recognized that federal adjudication may, in certain circumstances, unduly interfere with ongoing state proceedings such that abstention is necessary to "accord[] appropriate deference to the 'respective competence of the state and federal court systems.'" England v. Louisiana State Bd. of Med. Examiners, 375 U.S. 411, 415 (1964) (quoting Louisiana Power & Light Co. v. City of Thibodaux, 360 U.S. 25, 29 (1959)). Gonzalez v. Waterfront Commission of New York Harbor, (3rd Cir. 2014).
The abstention doctrine set forth in Younger v. Harris, 401 U.S. 37 (1971), applies when three criteria are met: "(1) the dispute should involve an 'ongoing state judicial proceeding;' (2) the state must have an important interest in regulating the subject matter of the claim; and (3) there should be an 'adequate opportunity in the state proceedings to raise constitutional challenges.'" Wightman v. Tex. Supreme Court, 84 F.3d 188, 189 (5th Cir. 1996). Perez v. Texas Medical Board, (5th Cir. 2014).
Younger abstention is an exception to the general rule that federal courts must hear and decide cases within their jurisdiction. The doctrine reflects a concern that federal interference with certain types of important state proceedings is unwise and unnecessary in a system of dual sovereigns, id. at 44, and it requires that federal courts dismiss such cases rather than intervene in state affairs. As the Supreme Court has recently emphasized, Younger abstention is called for in exactly three classes of cases: where federal jurisdiction would intrude into ongoing state criminal proceedings, or into certain civil enforcement proceedings (judicial or administrative) akin to criminal prosecutions, or into civil proceedings "that implicate a State's interest in enforcing the orders and judgments of its courts." Sprint Communications, Inc. v. Jacobs, 134 S. Ct. 584, 588 (2013). Mulholland v. Marion County Election Board, (7th Cir. 2014).
Outside these three "exceptional" situations, Younger abstention is not appropriate even when there is a risk of litigating the same dispute in parallel and redundant state and federal proceedings. Id. at 591; Nader v. Keith, 385 F.3d 729, 732 (7th Cir. 2004). (The problems posed by parallel state and federal proceedings are managed under the narrower abstention doctrine of Colorado River Water Conservation Dist. v. United States, 424 U.S. 800 (1976), which ordinarily calls for a stay rather than dismissal when it applies, but still prevents duplication.) Mulholland v. Marion County Election Board, ibid.
THIS CASEBOOK contains a selection of 39 U. S. Court of Appeals decisions that analyze and interpret the Younger Abstention doctrine. The selection of decisions spans from January 2010 to the date of publication.