Law School Case Brief
Younger v. Harris - 401 U.S. 37, 91 S. Ct. 746 (1971)
The normal thing to do when federal courts are asked to enjoin pending proceedings in state courts is not to issue such injunctions.
Appellee Harris, who had been indicted for violating the California Criminal Syndicalism Act, sued in the Federal District Court to enjoin appellant, the county District Attorney, from prosecuting him, contending that the Act is unconstitutional on its face and inhibits him in exercising his free-speech rights. Appellees Dan and Hirsch, claiming that the prosecution of Harris would "inhibit" them from peacefully advocating the program of the political party to which they belonged, and appellee Broslawsky, a college professor, claiming that the prosecution made him "uncertain" as to whether his teaching and reading practices would subject him to prosecution, intervened as plaintiffs. All asserted that they would suffer irreparable injury unless a federal injunction was issued. A three-judge court, relying on Dombrowski v. Pfister, 380 U.S. 479, held the Act void for vagueness and overbreadth, and enjoined Harris' prosecution.
Was the decision to enjoin Harris’ prosecution justified in light of the alleged vagueness and overbreadth suffered by California Criminal Syndicalism Act?
The Court held that the possible unconstitutionality of the state statute on its face did not in itself justify an injunction against good-faith attempts to enforce it, and that since the threat to the Harris’ federal constitutional rights could be eliminated by his defense against a single criminal prosecution, and the only injury which he faced in connection with the state prosecution was that incidental to every criminal proceeding brought lawfully and in good faith, the District Court's injunction violated the federal policy forbidding federal courts from enjoining pending state criminal proceedings except under extraordinary circumstances where the danger of irreparable injury is great and immediate.
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