Law School Case Brief
Pa. Ass'n for Retarded Children v. Pennsylvania - 343 F. Supp. 279 (E.D. Pa. 1972)
The doctrine of abstention applies in narrow circumstances where a decision concerning a question of state law might be adequate to dispose of the case or may change the precise nature of the constitutional questions presented, and the answer to the state question involves unclear state law. Where there is no question of unclear state law, however, a federal court may not abstain merely because (1) state courts are as competent a forum to decide federal questions as are the federal courts, or (2) paramount state interests are challenged in the suit.
Plaintiffs, parents of retarded children and association, brought a class action against defendants, Commonwealth and school districts (defendant class), challenging several statutes, which excluded children with disabilities from a program of education and training in the public schools. Plaintiffs alleged that the statutes were constitutionally infirm both on their faces and as applied. After a consent agreement was reached, defendant objector challenged the personal and subject matter jurisdiction of the court and raised the issue of abstention.
Should the district court abstain from hearing the case?
The Court held that abstention was not required because certain of the challenged statutes violated due process on its face. Even though the issue of whether the statutes violated the state equal protection laws was unclear, no finding was made on the constitutionality of the statutes due to the consent agreement. Further, entry of the agreement would not create friction between the state and federal governments because the state officials urged the court to not abstain.
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