Application of the Younger abstention doctrine is mandated not only when the pending state proceedings are criminal, but also when certain civil proceedings are pending, if the state's interests in the proceeding are so important that exercise of the federal judicial power would disregard the comity between the states and the national government.
Appellant company obtained a state court judgment for actual and punitive damages against appellee company, alleging that appellee tortiously induced a third party to breach a contract for sale of stock to appellant. Because it lacked resources to post a bond suspending execution of judgment pending appeal, appellee filed an action in federal district court just before entry of judgment, alleging that the state proceedings violated its constitutional and statutory rights, and sought to enjoin enforcement of the judgment. The district court issued a preliminary injunction and the court of appeals affirmed.
Did the lower federal courts err in issuing an injunction instead of abstaining?
The court reversed and remanded with instructions to vacate the injunction and dismiss appellee's complaint, holding that the lower federal courts should have abstained under the Younger doctrine. The court reasoned that there was no basis for concluding that the state procedures were inadequate to adjudicate appellee's constitutional claims because appellee had neither given the state courts an opportunity to adjudicate its claims nor demonstrated that the state courts were not open to adjudicate them; thus, abstention was required under principles of comity.