Younger v. Harris

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Younger v. Harris was decided by the U.S. Supreme Court on February 23, 1971. John Harris Jr. had been indicted in a California state court and charged with violation of the California Criminal Syndicalism Act. He filed a complaint in the federal district court seeking an injunction to restrain Evelle J. Younger, the state district attorney, from proceeding with the prosecution on the grounds that it infringed upon his rights of free speech and press as guaranteed by the First and Fourteenth Amendments of the U.S. Constitution.

A three-judge panel of the appropriate federal district court granted the injunctive relief restraining Younger from prosecuting the pending state criminal action. The panel also held that the California Criminal Syndicalism Act was void for vagueness and overbreadth in violation of the U.S. Constitution.

The U.S. Supreme Court reversed the district court panel, holding that enjoining Younger from prosecuting the California statutes was a violation of the national policy prohibiting federal courts from enjoining state court proceedings except in special circumstances that were not applicable to this case.

The Court reasoned that since the founding of the United States, Congress has manifested a desire to permit state courts to try state cases free from interference by federal courts. The Court explicitly noted that there had been only three congressional and one judicial exception to the general rule prohibiting federal interference with state court proceedings. The opinion recognized the exceptions as (1) when expressly authorized by Act of Congress, (2) where necessary in aid of the federal court’s jurisdiction, and (3) to protect or effectuate judgments of the federal court. The judicial exception, allowing federal interference with a state criminal proceeding, was described as where a person about to be prosecuted in a state court could show that, unless the state prosecution was enjoined, he would suffer irreparable damages. None of the exceptions was present in Younger.

The Younger opinion explicitly recognized that the underlying reason for prohibiting the district court from interfering with state criminal prosecutions was the notion of “comity, i.e., a proper respect for state functions in recognition of the fact that America is composed of a union of separate state governments which should be left free to perform their separate functions in their separate ways.” This relationship between the federal and state governments was described by the Court as “our federalism.”

“Our federalism” was described as representing a system in which there is a sensitivity to the legitimate interests of both the state and national governments, protecting federal rights and interests, but endeavoring to do so in ways that will not unduly interfere with the legitimate sphere of influence or the states.

Charles D. Cole

Last Updated: 2006

SEE ALSO: Abstention; Comity; Michigan v. Long; New Judicial Federalism