Yes. That special civil rights law is an exception. There is an old law called the Anti-Injunction Act that usually stops federal courts from meddling in state court cases. However, Congress can create exceptions. The Court found that Section 1983, a law passed after the Civil War, was meant to be one of those exceptions. The whole reason for Section 1983 was to let federal courts protect people's constitutional rights from being violated by state officials, including state judges. Therefore, federal courts do have the power to stop a state case under this law. But, the Court added that federal judges should still be very respectful and cautious before they decide to interfere with a state court.

Yes, I agree, but let's be very clear. All we are saying today is that the Anti-Injunction Act doesn't automatically block this kind of lawsuit. We are NOT saying the federal court must stop the state case. The federal judge still has to think hard about whether it's appropriate to interfere, based on principles of respect for the state government. This decision just opens the courthouse door; it doesn't guarantee a win.

Yes, a federal court can stop a state court case under § 1983. Congress made § 1983 to let federal courts step in between states and the people to guard people's federal rights. It's meant to protect people from state actions that go against the Constitution, whether those actions come from the state's executive branch, legislative branch, or courts. In § 1983, Congress clearly allowed federal courts to issue orders stopping state court cases when needed to prevent serious and permanent harm to someone's constitutional rights.

I agree with the Court's opinion, but I want to stress what the Court is and isn't deciding. The Court is only saying that the law that normally stops federal courts from interfering with state court cases (28 U.S.C. § 2283) doesn't apply to § 1983 cases. But the Court isn't changing the principles of fairness, respect between state and federal courts, and federalism that should still make federal courts be very careful about stopping state court cases. When this case goes back to the lower federal court, that court should think carefully about whether those principles mean it shouldn't stop the state court case here, even though it has the power to do so under § 1983.

Yes. 42 U.S.C. § 1983 is an 'expressly authorized' exception to the Anti-Injunction Act. The Court established a test for what qualifies as an 'expressly authorized' exception: an Act of Congress must have created a specific and uniquely federal right or remedy, enforceable in a federal court of equity, that could be frustrated if the federal court were not empowered to enjoin a state court proceeding. The Court reasoned that § 1983's predecessor, the Civil Rights Act of 1871, was enacted specifically to enforce the Fourteenth Amendment and alter the traditional relationship between state and federal courts. Its legislative history shows Congress's intent to 'interpose the federal courts between the States and the people' to protect federal rights against state action, including judicial action. Because the very purpose of § 1983 was to provide a federal remedy for the deprivation of federal rights by state actors, it meets the test for an exception. However, this holding does not eliminate the constraints of equity, comity, and federalism, as articulated in Younger v. Harris, which still must guide a federal court's decision on whether to issue an injunction.

Yes. This concurrence emphasizes the narrowness of the Court's holding. The decision only establishes that the Anti-Injunction Act does not apply to suits brought under § 1983. It does nothing to 'question or qualify in any way the principles of equity, comity, and federalism that must restrain a federal court when asked to enjoin a state court proceeding.' On remand, the District Court must still properly consider whether general equitable principles and federalism, similar to those in Younger v. Harris, prevent the issuance of an injunction in this specific civil case.

Yes. The federal anti-injunction statute does not bar injunctions against state court proceedings in suits brought under 42 U.S.C. § 1983 because this Act of Congress falls within the 'expressly authorized' exception of the anti-injunction statute. The very purpose of § 1983 was to interpose the federal courts between the States and the people, as guardians of the people's federal rights — to protect the people from unconstitutional action under color of state law, 'whether that action be executive, legislative, or judicial.' Ex parte Virginia, 100 U. S., at 346. In carrying out that purpose, Congress plainly authorized the federal courts to issue injunctions in § 1983 actions, by expressly authorizing a 'suit in equity' as one of the means of redress. And this Court long ago recognized that federal injunctive relief against a state court proceeding can in some circumstances be essential to prevent great, immediate, and irreparable loss of a person's constitutional rights.

I concur in the opinion of the Court and add a few words to emphasize what the Court is and is not deciding today as I read the opinion. The Court holds only that 28 U.S.C. § 2283, which is an absolute bar to injunctions against state court proceedings in most suits, does not apply to a suit brought under 42 U.S.C. § 1983 seeking an injunction of state proceedings. But, as the Court's opinion has noted, it does nothing to 'question or qualify in any way the principles of equity, comity, and federalism that must restrain a federal court when asked to enjoin a state court proceeding.' On remand in this case, it seems to me the District Court, before reaching a decision on the merits of appellant's claim, should properly consider whether general notions of equity or principles of federalism, similar to those invoked in Younger, prevent the issuance of an injunction against the state 'nuisance abatement' proceedings in the circumstances of this case.

Mitchum v. Foster

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