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The principles of Younger v. Harris are fully applicable to noncriminal proceedings when important state interests are involved. Where vital state interests are involved, a federal court should refrain from enjoining an ongoing state judicial proceeding unless state law clearly bars the interposition of constitutional claims, or some extraordinary circumstance exists requiring equitable relief.
Applicants, the Hawaii Housing Authority, its commissioners and executive director, request the Court to stay or vacate an order of the United States Court of Appeals for the Ninth Circuit. The present application bears only tangentially on the merits of the underlying lawsuit, in which the Court of Appeals decided that the condemnation provisions of the Hawaii Land Reform Act, Haw. Rev. Stat. § 516-1 et seq. (1976 and Supp. 1982), violated the "Takings Clause" of the Fifth Amendment to the United States Constitution. Applicants have appealed to the Court from that ruling, and their jurisdictional statement will be considered by this Court in due course. This application arises out of the decision of the Court of Appeals on August 11, some four months after its opinion on the merits was issued, to recall its mandate for clarification and, pending such clarification, to enjoin applicants from pursuing or initiating any state administrative or judicial proceedings under the Hawaii Land Reform Act.
Should the application requesting the stay or vacation of an order of the United States Court of Appeals be granted?
Denying the application, the Court noted that, although the order contained no findings such as those contemplated by Federal Rule of Civil Procedure 65, the court of appeals obviously contemplated possible modification of its injunction in the near future. A stay based on this contention was inappropriate. Applicants' third contention raised the most serious question: whether the injunction against further state proceedings violated the principles of federalism. The Court determined that it would be an inappropriate exercise of authority to stay an order of the court of appeals which was not demonstrably wrong and which that court itself might be disposed to revise.