Trainor v. Hernandez - 431 U.S. 434, 97 S. Ct. 1911 (1977)

Rule:

The precondition for equitable relief of irreparable injury is not be satisfied unless the threatened injury is both great and immediate. The burden of conducting a defense in a criminal prosecution is not sufficient to warrant interference by the federal courts with legitimate state efforts to enforce state laws; only extraordinary circumstances suffice. To restrain a state proceeding that affords an adequate vehicle for vindicating the federal plaintiff's constitutional rights entails an unseemly failure to give effect to the principle that state courts have the solemn responsibility equally with the federal courts to safeguard constitutional rights and reflects negatively upon the state court's ability to do so. The State would be prevented not only from effectuating its substantive policies, but also from continuing to perform the separate function of providing a forum competent to vindicate any constitutional objections interposed against those policies.

Facts:

Alleging that public assistance recipients had fraudulently concealed assets while applying for and receiving their welfare payments, conduct which constituted a crime under Illinois law, the Illinois Department of Public Aid brought a civil action against the welfare recipients in the Circuit Court of Cook County, Illinois. Contemporaneously with such suit to obtain the return of money alleged to have been wrongfully received, the Department instituted attachment proceedings under the Illinois Attachment Act against the property of the welfare recipients. Thereafter, the clerk of the Circuit Court issued a writ of attachment which the sheriff executed on the welfare recipients' money in a credit union. The welfare recipients did not file an answer to the attachment or the underlying complaint and did not attempt to quash the attachment on the ground that the procedures surrounding its issuance rendered it and the Illinois attachment statutes unconstitutional, but, instead, brought a civil rights class action under 42 U.S.C.S 1983 in the United States District Court for the Northern District of Illinois, seeking declaratory and injunctive relief against various state officials. The three-judge District Court, finding that the case was not one governed by the doctrine of abstention whereby a federal court will refrain from interfering in pending state proceedings for reasons of federalism and comity, held that the Illinois Attachment Act violated the due process clause of the Fourteenth Amendment. The Department, court clerks, and sheriffs sought review, claiming that under Younger and Huffman principles the district court should have dismissed the suit without passing on the constitutionality of the Act and that the Act was constitutional. 

Issue:

Under the circumstances, should the federal court have refrained from interfering in the pending state proceedings? 

Answer:

Yes.

Conclusion:

The Court reversed and remanded, holding that the District Court should have abstained, under principles of federalism and comity, from entertaining the action on behalf of either the named or unnamed plaintiffs, and should have dismissed the complaint rather than interfering with the ongoing state civil enforcement action, which the state had brought in its sovereign capacity, unless the public aid recipients' remedies in the state proceedings were inadequate to litigate their claims under the United States Constitution, there being no extraordinary circumstances which would otherwise warrant federal court interference, since there was no suggestion that the pending state action was brought in bad faith or for the purpose of harassing the welfare recipients, and since the challenged attachment statute was not flagrantly and patently violative of express constitutional prohibitions in every clause, sentence, and paragraph, and in whatever manner and against whomever an effort might be made to apply it.