Hicks v. Miranda

Supreme Court of the United States · 1975 · Federal Courts

Federal CourtsYounger abstentionThree-judge courtsSummary dispositionsYounger v. HarrisSamuels v. Mackellabstentionpending state prosecution

Facts

Police seized four copies of "Deep Throat" from appellees' theater under four separate warrants, and state criminal charges were first filed against two theater employees. The next day after service of the federal complaint was completed, the state amended the criminal complaint to add appellees as defendants and added conspiracy counts. Meanwhile, a California superior court had already declared the film obscene and ordered all copies at the theater seized, and appellees did not appeal that order. The federal suit sought to declare the California obscenity statute unconstitutional, enjoin its enforcement, and require return of the seized films.

Issue

Whether the federal court should have dismissed the action under Younger and Samuels once state criminal proceedings were pending against appellees before any substantial federal merits proceedings occurred, and whether the District Court could disregard the Supreme Court's summary dismissal in Miller II. Also, whether the Supreme Court had direct appellate jurisdiction over the three-judge court's injunction.

Rule

A Supreme Court summary dismissal for want of a substantial federal question is a merits determination that lower federal courts must follow unless later doctrinal developments indicate otherwise. Under Younger, federal courts must abstain when state criminal proceedings are begun against the federal plaintiffs after the federal complaint is filed but before any proceedings of substance on the merits have taken place in federal court, absent extraordinary circumstances such as proven bad faith or harassment.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Portland, Oregon, Nora Patel owns an art-house theater. She files a federal suit seeking declaratory and injunctive relief against enforcement of an Oregon criminal exhibition statute after police seize one print of a film, but before any charges are brought against her. Three days later, and before the federal court holds any merits hearing or rules on any dispositive motion, state prosecutors charge Nora under the same statute.

Should the federal court abstain from reaching the merits?

Explanation. The majority held that Younger applies 'in full force' when state criminal proceedings are begun against the federal plaintiffs after the federal complaint is filed but before any proceedings of substance on the merits have taken place in federal court. The rule is not limited to cases where the prosecution was pending on the exact filing date. Thus, absent satisfactory proof of an exception such as bad faith or harassment, the federal case should be dismissed.