Gibson v. Berryhill - 411 U.S. 564, 93 S. Ct. 1689 (1973)

Rule:

Although a district court is not absolutely barred by statute from enjoining a state court proceeding when called upon to do so in a 42 U.S.C.S. § 1983 suit, the principles of equity, comity, and federalism must, under appropriate circumstances, restrain a federal court from issuing such injunctions. First of all, there is the doctrine, usually applicable when an injunction is sought, that a party must exhaust his available administrative remedies before invoking the equitable jurisdiction of a court. Secondly, there is the basic principle of federalism that a federal court may not enjoin a pending state criminal proceeding in the absence of special circumstances suggesting bad faith, harassment, or irreparable injury that is both serious and immediate. And finally, there is the doctrine that when confronted with issues of constitutional dimension which implicate or depend upon unsettled questions of state law, a federal court ought to abstain and stay its proceedings until those state law questions are definitively resolved.

Facts:

The Alabama Optometric Association, which excluded from membership all optometrists employed by other persons or entities, and thereby denied membership to 92 of the 192 practicing optometrists in Alabama, filed charges with the Alabama Board of Optometry against salaried optometrists of the Lee Optical Company, seeking revocation of their licenses for unethical conduct in practicing optometry as employees of a business corporation. Two days later, the Alabama Board of Optometry, composed solely of members of the Alabama Optometric Association, brought a state court suit against the Lee Optical Company, seeking to enjoin it from the unlawful practice of optometry, and naming as parties defendant 13 optometrists employed by the company, who were charged with unethical conduct very similar to that charged by the Association in its complaint to the Board. The state court dismissed the suit as to the individuals, but enjoined the company from practicing optometry without a license and from employing licensed optometrists. About 2 weeks before the scheduled Board hearings in the license revocation proceedings against the individuals, the individuals brought suit in the United States District Court for the Middle District of Alabama under 42 USCS 1983 against the Board, its individual members, the Association and other individuals, seeking to enjoin the license revocation hearings on the ground that the Board was biased and could not provide a fair hearing as required by the due process clause. The District Court enjoined the Board from conducting the hearings and revoking the licenses. The Supreme Court of Alabama later reversed the state court injunction against the company, holding that Alabama law did not preclude a licensed optometrist from being employed by another.

Issue:

1. Did the district court err in holding that the Board was biased and could not provide a fair hearing as required by the due process clause? 
2. Could the injunction still stand even in light of the Alabama Supreme Court's decisions? 

Answer:

1) No. 2) No.

Conclusion:

 The Court vacated the judgment and remanded the case for reconsideration in light of the Alabama Supreme Court's judgment in the Lee Optical case and a companion case. The Court held that the District Court was not precluded from adjudicating the issues before it. The Court further held that the District Court properly found that the Board was constitutionally disqualified by possible personal benefit from hearing the charges filed against the optometrists. However, the Court held that considerations of equity, comity, and federalism warranted vacating the District Court's judgment and remanding it for reconsideration in light of the Alabama Supreme Court's decisions.