No, a federal court cannot tell a state to stop a trial that's already happening, except in rare cases. The Court said that federal and state courts have their own jobs, and they should respect each other. This idea is called 'Our Federalism.' If Harris thinks the law is unconstitutional, he can make that argument in his state court trial. The only time a federal court should step in is in extreme situations, like if the prosecutor is charging someone just to be mean or to harass them, which wasn't happening to Harris.

No, federal courts should stay out of ongoing state criminal cases. These judges agreed with the result but wanted to be extra clear that this rule is about criminal cases that are already in progress. They said the Court wasn't deciding what to do about future cases or non-criminal (civil) cases. A federal court should only step in if the state is acting in 'bad faith' or the law is ridiculously and obviously unconstitutional.

No, the federal court was wrong to get involved. These judges agreed Harris's case should be thrown out of federal court because he could make his arguments in state court. They also pointed out that the other three people who joined the lawsuit shouldn't have been allowed to sue, because nobody was actually threatening to charge them with a crime. You can't sue just because you 'feel' scared by a law.

Yes, the federal court should have stopped the trial. These judges argued that the California law was so obviously unconstitutional and bad for free speech that the federal court had a duty to protect Harris. They believed that a key purpose of federal courts is to protect people's civil rights from unfair state laws, and they shouldn't just stand by and watch an unconstitutional prosecution happen.

The Supreme Court reversed the Federal District Court's decision. It said the federal court should not have stopped the state criminal case against Harris unless there were extraordinary circumstances, which Harris didn't show here. The Court emphasized that federal courts should respect state courts and not interfere with state criminal cases, because of principles of federalism - the idea that the federal government and state governments have separate roles and powers. The Court said Harris hadn't shown that the prosecution was in bad faith or harassment. It also said the other people didn't have a real case because they hadn't actually been prosecuted and just feeling afraid wasn't enough reason for a federal court to step in.

Justice Douglas disagreed. He argued that a federal law doesn't stop federal courts from blocking enforcement of state laws that are unconstitutional on their face, which the Court had previously said the California law was. Douglas said that constitutional amendments and civil rights laws passed after the Civil War changed the balance of power between federal and state governments and allowed federal courts to protect constitutional rights from state violations. He would have approved the federal court's order because he thought the state law was unconstitutional and the people had shown enough evidence of bad faith enforcement and harassment by the state officials.

Justices Stewart and Harlan agreed with the result, but for slightly different reasons. They also thought federal courts generally shouldn't interfere with ongoing state criminal cases unless there are exceptional circumstances like bad faith, harassment, or a clearly unconstitutional state law. But they pointed out the Court's decision was limited to ongoing prosecutions and didn't decide whether federal courts could block future prosecutions or get involved in state civil cases.

Justices Brennan, White, and Marshall agreed that the federal court was wrong to intervene in Harris's case because he could make his constitutional arguments in the state court case, which wasn't shown to be brought in bad faith. But they thought the federal court also shouldn't have ruled on the other people's claims because they hadn't shown they were actually at risk of being prosecuted under the law.

—a federal court should not interfere with ongoing state criminal proceedings absent extraordinary circumstances

The Supreme Court has "generally direct [ed] federal courts to abstain from granting injunctive or declaratory relief that would interfere with pending state judicial proceedings."

—"the Supreme Court held that absent extraordinary circumstances, federal courts must abstain from enjoining ongoing state criminal proceedings."

—federal court should abstain from exercising jurisdiction over claims asking the court to interfere in ongoing state criminal proceedings

Even where the Younger test is met, the District Court may interfere with a state proceeding in certain extraordinary circumstances, such as where irreparable injury is "both great and immediate," where the state law is "flagrantly and patently violative of express constitutional prohibitions," or where there is a showing of "bad faith, harassment, or... other unusual …

—federal courts must abstain from hearing federal constitutional claims that may interfere with ongoing state criminal proceedings.

Accordingly, "the normal thing to do when federal courts are asked to enjoin pending [state criminal] proceedings... is not to issue such injunctions."

The Younger Court noted that courts of equity should not act unless the moving party has no adequate remedy at law and will suffer irreparable injury if denied equitable relief.

Comity requires `"a proper respect for state functions, a recognition of the fact that the entire country is made up of a Union of separate state governments, and a continuance of the belief that the National Government will fare best if the States and their institutions are left free to perform their separate functions in their separate ways.'"

For example, where a party brings a claim for damages under 42 USC § 1983, as well as a request for equitable relief from a state court proceeding, a federal district court should dismiss the claims for equitable relief under Younger, but stay the complaint with respect to the damages claim, because § 1983 is a federal cause of action.

Yes, the principles of comity and 'Our Federalism' generally prevent a federal court from enjoining a pending state criminal prosecution except under extraordinary circumstances. The court reasoned that a long-standing public policy, based on principles of equity and comity, prohibits federal courts from interfering with state court proceedings. A defendant can raise constitutional defenses within the state prosecution, which constitutes an adequate remedy at law, precluding equitable relief like an injunction. The mere cost and anxiety of a single, good-faith prosecution does not constitute the 'great and immediate' irreparable injury required to justify federal intervention. The court distinguished Dombrowski v. Pfister, limiting its exception to cases involving proven bad faith or harassment, which Harris did not allege.

Yes, federal courts should not intervene in pending state criminal prosecutions except in extremely limited circumstances. This concurrence stresses that the decision is based on policy grounds of federalism, not the federal anti-injunction statute (28 U.S.C. § 2283). The opinion clarifies that the ruling does not address federal intervention in state civil cases or against future (as opposed to pending) criminal prosecutions. The narrow exceptions requiring intervention exist only for situations of bad faith, harassment, or a patently and flagrantly unconstitutional statute.

Yes, federal intervention was improper in this case. This concurrence agrees with the outcome because Harris had an adequate forum in the state court to adjudicate his constitutional claims and had not alleged bad faith. It further reasons that the other plaintiffs (Dan, Hirsch, and Broslawsky) lacked standing to sue because they faced no threat of prosecution. Their 'chilling effect' claims were too speculative to create a live Art. III controversy.

No, the principles of federalism do not prevent an injunction when a prosecution is brought under a facially unconstitutional statute that chills First Amendment rights. The dissent argues that the majority misreads Dombrowski, which allows for federal intervention to prevent the 'chilling effect' of an overbroad statute on First Amendment rights, not just in cases of bad faith. The California statute is patently unconstitutional under the precedent of Brandenburg v. Ohio. Furthermore, the dissent contends that 42 U.S.C. § 1983 provides an 'expressly authorized' exception to the federal anti-injunction statute, making the injunction legally permissible and necessary to protect fundamental rights.

The Supreme Court reversed the judgment of the District Court, holding that the federal court should not have enjoined the pending state criminal prosecution except under extraordinary circumstances not present here. The Court emphasized the importance of federal courts not interfering with state criminal prosecutions based on principles of equity, comity, and federalism. The Court stated that federal courts should restrain their authority because of "proper respect for state functions" and the belief that the national government "will fare best if the States and their institutions are left free to perform their separate functions in their separate ways." The Court found that Harris had not alleged or shown the kind of extraordinary circumstances, such as bad faith prosecution or harassment, that would justify federal intervention. The Court also held that the other plaintiffs did not have an actual controversy based on the prosecution of Harris and their allegations of feeling inhibited, without more, were not sufficient for the federal court to restrain the state prosecution.

Justice Douglas dissented, arguing that the federal anti-injunction statute, 28 U.S.C. § 2283, does not bar federal courts from enjoining enforcement of state statutes that are unconstitutional on their face, as the California Criminal Syndicalism Act was previously held to be by the Court. Douglas stated that the Civil War Amendments and civil rights statutes like 42 U.S.C. § 1983 altered the balance of federalism and allowed federal courts to protect federal constitutional rights from state infringement. He would have upheld the injunction because the state statute was unconstitutional and the plaintiffs, in his view, had sufficiently alleged bad faith enforcement and harassment by the state officials.

Justices Stewart and Harlan concurred in the judgment, agreeing that federal courts should not intervene in pending state criminal prosecutions absent exceptional circumstances like bad faith, harassment, or a flagrantly unconstitutional state statute. However, they noted the Court's decision was limited to pending prosecutions and did not resolve whether the anti-injunction statute would apply or preclude injunctions against future prosecutions or in civil contexts.

Justices Brennan, White, and Marshall concurred in the result, agreeing that the federal court improperly intervened as to Harris because he could raise his constitutional claims in the pending state prosecution, which was not alleged to have been brought in bad faith. However, they would have held that the other plaintiffs had not established an actual controversy justifying an injunction because they had not shown a reasonable expectation of being prosecuted under the statute for their desired activities.

Younger v. Harris

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