Younger Abstentation of federal court: 3-part checklist

2.8.A.2. The Three-Part Test for Applying Younger

A number of federal courts have adopted, in slightly varying formulations, a three-part threshold test derived from Middlesex County Ethics Committee for assessing the propriety of invoking Younger./231/ Under this analysis, absent extraordinary circumstances inherent in the exceptions stated in Younger, abstention is generally proper when three standards are met: (1) there are ongoing state adjudicative proceedings, which (2) implicate important state interests, and which (3) provide an adequate opportunity to raise the plaintiff’s federal claims./232/

These factors have generated varying amounts of case law in the lower courts. We examine them in reverse order, addressing first those issues most likely to occur in litigation pursued by legal services advocates. With respect to the third Middlesex factor, a key assumption of the Younger doctrine is that plaintiffs should be able to assert federal defenses to a state proceeding in the course of that proceeding./233/ If the underlying state proceedings do not afford plaintiffs a meaningful opportunity to present their federal claims, then abstention is not appropriate./234/ Thus, in Dayton Christian Schools, a question arose as to whether the federal court plaintiffs could have raised their First Amendment defense in the course of the state proceeding./235/ The Court assumed that they could not, but it nonetheless observed that the school could have raised its federal claims in the state court appeal of any state administrative orders./236/

Many lower federal court decisions have since hinged their Younger abstention analyses upon finding the state forum to be an adequate outlet for the raising of federal claims. For example, in affirming abstention in a suit seeking an injunction against the prosecution of a state attorney discipline complaint, the Sixth Circuit held that the state proceedings gave adequate opportunities for the plaintiff to raise his constitutional challenges to the grievance procedures./237/ The court noted that, even if the attorney disciplinary board could not declare a rule of professional conduct unconstitutional, the board could still refuse to enforce the rule or otherwise narrowly construe it./238/ Similarly, in another challenge to lawyer disciplinary proceedings, the Ninth Circuit found Younger to be satisfied, notwithstanding that the state constitution precluded the bar from considering federal constitutional claims, because discretionary state judicial review was available./239/

The adequate state forum factor also frequently arises in the specific context of institutional reform litigation raising systemic constitutional challenges to the administration of state agency or court proceedings. These cases generally present the issue of whether broad-ranging federal court challenges to procedural deficiencies in child welfare, public benefits, and other adjudicatory systems should be dismissed due to asserted opportunities for plaintiffs to raise these same systemic claims in the very state court and administrative hearings that form the bases for the litigation. The decisions have produced somewhat mixed outcomes./240/

Courts frequently give short shrift to the second Middlesex factor regarding the implication of important state interests. While many state interests can conceivably be said to relate to significant guarantees of public health, safety, and welfare, it is important to closely analyze these declared interests. For example, after surveying numerous Younger abstention decisions reviewing various state interests, the court in Harper v. Public Service Commission discounted the state interest proffered by the defendant—the improper disposal of solid waste—and recast it as an actual state interest in limiting access of out-of-state companies to the waste removal market./241/ The court declined to allow Younger abstention, ruling that this state “interest” actually interfered with the comity and federalism concerns embodied in the Commerce Clause./242/ Similarly, the court in McCartney v. Cansler declined to abstain in a challenge to reductions or terminations of mental health and developmental disability services received by children eligible under the Medicaid Act, despite the plaintiffs’ pending administrative appeals, since the Medicaid program is subject primarily to federal law that outweighs state interests./243/

Finally, and not to be overlooked, the Younger doctrine logically assumes the existence of an ongoing state proceeding—the first Middlesex factor. This has generated a fair amount of discussion in the lower courts. If no state court proceeding is actually pending at the commencement of the federal litigation, declaratory, injunctive or compensatory relief may be available to the federal plaintiff./244/ In Ankenbrandt v. Richards, a diversity action brought by a mother on behalf of her children and alleging torts of physical and sexual abuse committed by her former husband and his companion, the Court held the application of Younger abstention to be erroneous since the state proceedings had concluded prior to the filing of the federal lawsuit./245/ The Court reasoned that Younger had never been applied “when no state proceeding was pending nor any assertion of important state interests made.”/246/

A determination of whether state proceedings are actually “pending” at the time of the federal action being brought can be confusing, especially in institutional reform cases./247/ While this determination may prove to be pivotal to the court’s decision to abstain,/248/ it is important to note that the actual order of the state and federal court filing dates alone may not solely influence the outcome of any abstention analysis. In Hicks v. Miranda, the Court held that, even where the state proceeding commences after the federal suit is filed, Younger still applies as long as the state proceedings were initiated “before any proceedings of substance on the merits have taken place in the federal court.”/249/

Although the Younger doctrine severely limits the federal court’s ability to enjoin pending state court proceedings, the mere existence of a state court proceeding with some relationship to the litigants or issues involved in a federal court case does not, standing alone, justify the invocation of Younger. The Younger abstention doctrine justifies, as “the normal thing to do,” the “withholding of authorized equitable relief because of undue interference with state proceedings. . . .”/250/ In ruling that parallel state and federal actions filed by the same plaintiff did not present a sufficient level of undue interference to allow abstention, the Eleventh Circuit stated in Wexler v. Lepore: “We interpret the Younger doctrine as preventing federal courts from being the grand overseers of state courts and court-like administration.”/251/ In modifying its prior influential ruling that the Middlesex three-part test is only triggered when federal court relief would directly ‘interfere’ with ongoing state proceedings,/252/ the Ninth Circuit acknowledged that, while “interference” with state proceedings is indeed a critical component of Younger’s comity concerns, “direct” interference is not necessarily a threshold element. Only a “federal court action that would enjoin the proceeding, or have the practical effect of doing so, would interfere in a way that Younger disapproves.”/253/ Other courts have adhered to the general principle of “interference” being a key component of the Younger analysis./254/

2.8.B. Pullman Abstention

When federal constitutional claims arise from unsettled issues of state law, federal courts have discretion to abstain from exercising jurisdiction. When they do so, the federal courts avoid predicting what state courts would decide and permit the state courts the first opportunity to interpret state law. Doing so may also dispose of the need of the federal court to decide the federal constitutional issue later.

2.8.B.1. The Pullman Doctrine

This aspect of abstention, known as Pullman abstention, was announced by the Supreme Court in Railroad Commission v. Pullman Co./255/ In Pullman, the railroad sued a state regulatory agency. The railroad challenged on Fourteenth Amendment grounds the requirement that all trains in Texas have a conductor in each sleeping car. Employment in the railroad industry was racially segregated; whites were employed as conductors, while African Americans performing similar work were employed as porters. Thus, the regulation had a discriminatory impact on African Americans.

The Court held that the authority of the regulatory agency to issue the challenged requirement was unclear under state law. Reasoning that resolution of the question could obviate the need to decide the constitutional issue, the Court ruled that the uncertain issue of state law should be resolved in state court before a federal court adjudicated the constitutional challenge. Thus, the Court in Pullman required the district court to abstain in order to enable the parties to litigate the unresolved question of state regulatory authority in state court.

Pullman abstention is, therefore, appropriate when (1) the federal court is presented with an ambiguous or uncertain provision of state law, and (2) state court interpretation of the state law issue may avoid the federal constitutional question./256/ Mere ambiguity in state law is insufficient—Pullman abstention also involves a “discretionary exercise of the court’s equity powers.”/257/ The Court has stated that “the relevant inquiry is not whether there is a bare, though unlikely, possibility that state courts might render adjudication of the federal question unnecessary.”/258/ Rather, the Court has “‘frequently emphasized that abstention is not to be ordered unless the statute is of an uncertain nature, and is obviously susceptible of a limiting construction.’”/259/ Thus, the ambiguity in state law must be of a type such that a clarifying construction could eliminate the need to reach the constitutional issue, or at least alter it substantially./260/

Because the purpose of Pullman abstention is to avoid the unnecessary decision of unsettled questions of constitutional law, its use is improper when “the unconstitutionality of the particular state action under challenge is clear.”/261/ For that same reason, many federal courts refuse to apply the doctrine in cases raising claims that clear state law is inconsistent with federal statutory law./262/ The Ninth Circuit has gone one step further, holding that preemption is not a constitutional issue justifying Pullman abstention. /263/ Since Pullman abstention necessarily results in delayed piecemeal adjudication, the Court is somewhat less inclined to sanction abstention in cases involving federal First Amendment challenges./264/

State constitutions frequently contain provisions similar to the substantive provisions of the United States Constitution. Those provisions could be an alternative basis under state law for enjoining challenged state conduct./265/ However, the Court has held that federal courts need not abstain to permit state courts to first address state constitutional provisions that are counterparts of federal provisions. The Court observed that a contrary rule “would convert abstention from the exception into the general rule.”/266/ In cases where states possess unique constitutional provisions with no federal counterpart, the Court has required abstention./267/

Advocates should be aware that the inclusion of supplemental state claims in a federal constitutional lawsuit increases the risk of Pullman abstention. If the supplemental claim offers an alternative basis for resolving the litigation and for obviating the need to construe the federal Constitution, its inclusion invites abstention./268/ Therefore, the increased risk of abstention should be taken into account before including a supplemental state law claim as an alternative basis for relief in constitutional litigation. Although the inclusion of supplemental claims can increase the risk of abstention, their omission does not eliminate the risk. If the state law that purportedly authorizes the challenged conduct is unclear, Pullman abstention remains a threat./269/ While a parallel state proceeding is not required for Pullman abstention, a pending state court action may in fact make it more likely that the federal court will abstain. In Ford Motor Company v. Meredith Motor Company, for example, the First Circuit found that the federal court plaintiff’s concurrently pending state court appeal of the underlying state agency decision constituted an additional factor justifying Pullman abstention. /270/ The court was persuaded by the state court of appeal’s potential to moot the federal issues and, consequently, stayed the federal action pending final review of the agency decision in the state court system./271/

2.8.B.2. England Reservations and Practice

Once a federal court invokes Pullman abstention, it generally should not dismiss the action, but instead retain jurisdiction and stay proceedings regarding the federal constitutional issues while the plaintiff litigates the unclear question of state law through the state courts./272/ In the state court action, the plaintiff must not only present the state law question, but must also ask the state court to construe it in light of the federal issue, which must itself be expressly reserved for subsequent litigation in federal court. This is called an “England reservation.”/273/ Failure to inform the state court of the reservation of the federal issue precludes a later return to federal court for its resolution./274/ Thus, following an order of abstention, the state court action must describe the nature of the federal constitutional issue in some detail, but must expressly reserve its determination for the federal court./275/

An express England reservation has three elements: (1) explicit expression to the state tribunal of an intent to return to federal court in the wake of an adverse state determination, if any; (2) explicit notification to the state tribunal of the federal questions that would be reserved, and (3) an absence of voluntary litigation in the state court by the reserving party of the federal questions that would be preserved for federal trial./276/

The Court’s decision in San Remo Hotel v. City and County of San Francisco emphasizes the critical nature of the third element of refraining from litigating the federal issues in the state tribunal./277/ The plaintiffs there had litigated their federal constitutional takings claims on remand to state court and had subsequently tried to avoid the preclusive effect of the state court judgment when they returned to federal court. The Supreme Court disallowed this, holding that “by broadening their state action” to include their federal claims, “petitioners effectively asked the state court to resolve the same federal issues they asked it to reserve. England does not support the exercise of any such right.”/278/ The Court held the plaintiffs to be subject to the full faith and credit statute, 28 U.S.C. § 1738, which barred them from re-litigating their federal claims in federal court./279/

2.8.B.3. State Certification as a Pullman Alternative

If the forum state has a procedure by which its highest court answers state law questions certified to it, a federal court can potentially obtain an authoritative ruling on ambiguous issues of applicable state law. Although certification procedures vary widely among the states, most states accept certified questions from the U.S. Supreme Court, any federal court of appeals, or any U.S. district court. Other states accept certified questions from specified federal courts./280/ Several states have no apparent procedure for the certification of questions of state law from the federal courts. State procedures to certify questions of state law to the state’s highest court can potentially shorten delays associated with Pullman abstention. In Arizonans for Official English v. Arizona, the Court discussed and endorsed the concept of state court certification of novel or unsettled questions of state law as a more suitable “cautious approach” which now covers territory once dominated by Pullman abstention. The Court found that this may also prove in practice to avoid the protracted, expensive litigation frequently associated with the doctrine./281/ Federal courts have exercised varying degrees of discretion to certify questions of state law to state courts. /282/

In a state with no available or adequate certification procedure, the delay associated with Pullman abstention requires a careful evaluation of whether the prospect of eventual return to district court is worth the wait. The alternative is to abandon the federal action and present both the state and federal issues to a state court for resolution in a single action. Although Pullman abstention can cause long delay, minimizing the impact of delay is possible in appropriate cases by seeking preliminary injunctive relief in the federal forum in the interim. Federal courts retain equitable power to issue preliminary relief to preserve the status quo while the parties seek clarification of state law in state court./283/

2.8.C. Burford Abstention

In Burford v. Sun Oil Company, the Supreme Court ordered the dismissal of a federal suit challenging the reasonableness under Texas law of a state commission’s decision to grant a permit to drill oil wells./284/ The Court created what has become known as Burford abstention to avoid the potentially disruptive impact that federal court intervention would have had on the state’s efforts to maintain a unique and complex administrative structure to regulate a vital state activity.

Defendants often attempt to rely on the language in Burford to assert a broader doctrine of abstention based simply on the existence of a complex state administrative or regulatory structure. Such an expansive reading of the Burford decision, however, ignores the many unique factors involved in Texas regulation of oil and gas, which the Court addressed in the decision. The reasonableness of the particular permit to drill oil wells at issue in Burford was not itself of “transcendent importance.”/285/ However, federal court review of reasonableness, under state law, “where the state had established its own elaborate review system for dealing with the geological complexities of oil and gas fields,” would have had “an impermissibly disruptive effect on state policy for the management of those fields.”/286/ Because the “exercise of equitable jurisdiction by comparatively unsophisticated Federal District Courts alongside state-court review had repeatedly led to ‘[d]elay, misunderstanding of local law, and needless federal conflict with the state policy,’” the Court in Burford held that abstention was warranted./287/

The Court in New Orleans Public Service Incorporated v. Council of New Orleans summarized the Burford abstention doctrine as follows:

Where timely and adequate state-court review is available, a federal court sitting in equity must decline to interfere with the proceedings or orders of state administrative agencies: (1) when there are “difficult questions of state law bearing on policy problems of substantial public import whose importance transcends the result in the case then at bar”; or (2) where the “exercise of federal review of the question in a case and in similar cases would be disruptive of state efforts to establish a coherent policy with respect to a matter of substantial public concern.”/288/

Burford does not require abstention, the Court emphasized, simply because a complex state administrative process exists. Nor does it mandate abstention in all situations where a federal ruling may potentially conflict with state regulatory law or policy./289/ Indeed, the Court in New Orleans Public Service concluded that Burford abstention was unwarranted in the case before it because federal adjudication of the plaintiff’s federal preemption claim relating to a city council rate decision and a related “pretext claim” would not result in undue interference with local regulatory policy concerns./290/ Even if injunctive relief was ordered against enforcement of the rate order, the Court noted, “‘there is … no doctrine requiring abstention merely because resolution of a federal question may result in the overturning of a state policy.’”/291/

The Court in Quackenbush v. Allstate Insurance Company, narrowly construed Burford abstention and described it as balancing the interest in retaining federal jurisdiction against the competing concern for the “independence of state action,” which, it noted,” only rarely favors abstention.”/292/ The Court acknowledged that it had “revisited the [Burford] decision only infrequently in the intervening 50 years.”/293/ The Court noted several factors “unique to that case”—the difficulty of the state regulatory issues, the need for uniform regulation in the oil and gas area and the important state interests served by this system, and, “most important[],”the “detrimental impact of ongoing federal court review of the [state agency’s] … orders, which review had already led to contradictory adjudications by the state and federal courts.”/294/

The Quackenbush Court considered whether Burford abstention supplied a proper basis for dismissal, as opposed to a stay, of federal actions presenting damages claims. Noting that prior abstention holdings did not supply a “formulaic test for determining when dismissal under Burford is appropriate,” the Court observed that the power to dismiss was based on discretionary doctrines of equity, comity, and federalism./295/ This had previously led the Court to allow “federal courts applying abstention principles in damages actions to enter a stay, but [the Court had] … not permitted them to dismiss the action altogether[.]”/296/ The Court held that, while “Burford might support a federal court’s decision to postpone adjudication of a damages action pending the resolution by the state courts of a disputed question of state law,” federal courts “have the power to dismiss or remand cases based on abstention principles only where the relief being sought is equitable or otherwise discretionary.”/297/

The class example of Burford abstention remains a challenge to a state utility regulatory system./298/ Burford abstention has also been upheld, however, in varied settings such as workers compensation, insurance, zoning, and related land use issues./ 299/ Burford abstention has been upheld in a Medicaid contract funding challenge,/300/ but other courts have refused to abstain in cases involving state agency curtailment of Medicaid services./301/ Defendants periodically attempt to rely on Burford in cases involving constitutional rights of individuals, but the courts are often reluctant to permit such an expanded use of Burford abstention./302 / The Second Circuit has stated: “Burford abstention is not required even in cases where the state has a substantial interest if the state’s regulations violate the federal constitution.”/303/

The Supreme Court has indicated a potential application of Burford in the area of state domestic relations law. In Ankenbrandt v. Richards, the Court addressed a tort action brought by a mother on behalf of her daughters against their father./304/ The Court stated that, even though the action did not fall within the “domestic relations” exception to federal jurisdiction, Burford abstention “might be relevant in a case involving elements of the domestic relationship even when the parties do not seek divorce, alimony, or child custody.”/305/ Difficult state law questions bearing on substantial public policy problems could be implicated “if a federal suit were filed prior to effectuation of a divorce, alimony, or child custody decree and the suit depended on a determination of the status of the parties.”/306/ Some federal courts have followed the suggestion of the Ankenbrandt Court by applying Burford abstention in the domestic relations area./307/

2.8.D. Colorado River Abstention

In Colorado River Water Conservation District v. United States, the Supreme Court established a fourth type of abstention applicable to situations when parallel state and federal litigation are pending./308/ Colorado River was a water rights case involving simultaneous state and federal court proceedings against the United States. Although the federal litigation did not fall within the Younger, Pullman, or Burford abstention doctrines, the Court held that, in a limited number of cases, federal courts should abstain because of the pendency of parallel and duplicative state court litigation. The Court observed that these cases are founded upon concerns of judicial administration, not the “weightier considerations” of comity and federalism that animate the other abstention doctrines./309/ Emphasizing “the virtually unflagging obligation of the federal courts to exercise the jurisdiction given them,” the Court nevertheless recognized that “exceptional” circumstances might permit a federal court to refrain from exercising jurisdiction “for reasons of wise judicial administration, in situations of concurrent state litigation.”/310/

Colorado River abstention is inapplicable unless there is parallel litigation./311/ The mere fact that the two lawsuits may involve different parties may not be enough to preclude abstention. For example, the Seventh Circuit noted that, “the requirement is of parallel suits, not identical suits” and treated a suit as parallel when “substantially the same parties are contemporaneously litigating substantially the same issue in another forum.”/312/ The Second Circuit, on the other hand, refused to apply Colorado River when the parties were not identical because the stay of the federal action would not necessarily avoid piecemeal litigation./313/ The Eighth Circuit has attempted to bring “more precision” to determining when state and federal proceedings are parallel, keeping in mind the limited reach of Colorado River abstention:

The pendency of a state claim based on the same general facts or subject matter as a federal claim and involving the same parties is not alone sufficient. Rather, a substantial similarity must exist between the state and federal proceedings, which similarity occurs when there is a substantial likelihood that the state proceeding will fully dispose of the claims presented in the federal court. . . . Moreover, in keeping with the Supreme Court’s charge to abstain in limited instances only, jurisdiction must be exercised if there is any doubt as to the parallel nature of the state and federal proceedings. /314/

The Colorado River decision identified four factors relevant to whether a federal court should abstain in favor of parallel state proceedings: (1) which court first assumes jurisdiction over property; (2) the inconvenience of the federal forum; (3) the desirability of avoiding piecemeal litigation, and (4) the order in which jurisdiction was obtained by the concurrent forums./315/ In Moses H. Cone Memorial Hospital v. Mercury Construction Corporation, the Court identified the following additional factors that courts must also consider in applying Colorado River: (1) the source of the governing law; (2) the adequacy of the state court action to protect federal rights; (3) the relative progress of the state and federal proceedings; (4) the presence or absence of concurrent jurisdiction; (5) the availability of removal, and (6) the vexatious or contrived nature of the federal claims./316/ The Court noted that these constituted merely “some of the factors.”/317/ In Moses H. Cone the Court cautioned that

the decision whether to dismiss a federal action because of parallel state-court litigation does not rest on a mechanical checklist, but on a careful balancing of the important factors as they apply in a given case, with the balance heavily weighted in favor of the exercise of jurisdiction. The weight to be given to any one factor may vary greatly from case to case, depending on the particular setting of the case./318/

Despite the potential for construing Colorado River abstention broadly, the Supreme Court has emphasized the narrowness of the doctrine. Federal courts have long permitted parallel litigation, using preclusion doctrines to limit re-litigation./319/ Moreover, in Moses H. Cone, the Court emphasized the limiting language in Colorado River and noted that pendency of a parallel state proceeding should not generally bar federal court proceedings./320/

However, the Supreme Court held in Wilton v. Seven Falls Company, a diversity action, that a standard of substantial discretion, rather than the Colorado River “exceptional circumstances” standard, governed a district court’s decision to stay a declaratory judgment action on grounds of a parallel state court proceeding./321/ This discretion is conferred upon the federal courts by the permissive language of the Declaratory Judgment Act./322/ The Court reaffirmed Brillhart v. Excess Insurance Company, which stated that district courts are “under no compulsion” to entertain claims of declaratory relief, since they possess discretion to exercise their jurisdiction under the Declaratory Judgment Act./323/ Thus, in contrast to Colorado River abstention, which allows a federal court to decline to exercise jurisdiction only under exceptional circumstances, the Brillhart doctrine, applicable to declaratory judgment actions, gives the district court broader discretion to determine “whether and when to entertain an action under the Declaratory Judgment Act, even when the suit otherwise satisfies subject-matter jurisdictional prerequisites.”/324/ The Wilton Court cautioned that its decision did not address the Brillhart doctrine’s “outer boundaries,” such as actions raising issues of federal law or cases without parallel state proceedings./325/

Simultaneously filing identical Section 1983 suits in state and federal courts potentially invites Colorado River abstention. More complicated issues arise when plaintiffs split their claims, seeking some relief in state court and other relief in federal court. The prohibition of such piecemeal litigation is one of the Colorado River factors, but, in an increasing number of cases, plaintiffs have no choice but to split claims if they wish to preserve access to federal court without abandoning meritorious state claims./326/

When plaintiffs must split their claims to avoid the Eleventh Amendment bar, they may lessen the likelihood of Colorado River abstention by delaying the filing of the state claim until substantial progress is made on the federal lawsuit. Delay in filing the state claim also minimizes the risk that the state case will be decided first and thereby acquire preclusive effect./327/ However, a plaintiff following this strategy must take care not to delay filing a state claim beyond the statute of limitations. For claims against the state, statutes of limitations are often short, but state tolling policies may extend these periods.

A less risky strategy may be to file both state and federal claims in federal court whenever there is an arguable basis for reading Pennhurst narrowly. Even if the federal court dismisses the state claim, the risk of a later, refiled state claim acquiring preclusive effect may be at least partially minimized.

2.8.E. The Rooker-Feldman Doctrine

Because lower federal courts do not have appellate jurisdiction over state courts, the Supreme Court refuses to permit losing state court litigants to invoke federal jurisdiction to attack state court judgments on the ground that the state court acted unconstitutionally./328/ This doctrine, often referred to as the Rooker-Feldman doctrine, originated in Rooker v. Fidelity Trust Co./329/ The Supreme Court reaffirmed the doctrine in District of Columbia Court of Appeals v. Feldman./330/

The Rooker-Feldman doctrine derives from 28 U.S.C. § 1257, which sets forth the exclusive means by which state court judgments are reviewable in federal court. The doctrine is also supported by the structure of the federal judicial system, in which only the Supreme Court of the United States has appellate jurisdiction over state court judgments. As a result, the doctrine bars “a party losing in state court … from seeking what in substance would be appellate review of the state judgment in a United States district court, based on the losing party’s claim that the state judgment itself violates the loser’s federal rights.”/331 / District courts may not review state court decisions “even if those challenges allege that the state court’s action was unconstitutional.”/332/


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