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 ("Act"), filed a lawsuit in a federal district court to enjoin appellant Younger, the District Attorney of Los Angeles County, from prosecuting him, contending that the Act was unconstitutional on its face and inhibited him from 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 that the Act was void for vagueness and overbreadth and enjoined Harris' prosecution.
Did the district court have authority to enjoin the state-court proceedings?
The United States Supreme Court reversed the trial court's judgment that a state law under which Harris had been indicted was unconstitutionally vague. 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 was great and immediate. Plaintiffs who joined in the action out of fear that their constitutional rights would be impaired did not have standing because they had not been indicted themselves. Although the statute may have challenged Harris' U.S. Const. amend. I freedom of speech rights and its enforcement might have a chilling effect on the speech of other persons, the Court could not review the statute on its face. The limited circumstances under which a statute threatened great and immediate irreparable injuries were not present.
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