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Younger v. Harris

Supreme Court of the United States · 1971 · Federal Courts
401 U.S. 37 (1971)
Updated
Federal Courtsabstentionpending state prosecutionscomityOur Federalismequityirreparable injurybad faith

Facts

John Harris, Jr. was indicted in California state court for violating the California Criminal Syndicalism Act and, while that prosecution was pending, sought a federal injunction against the district attorney. He alleged that the prosecution and the Act itself inhibited his First Amendment rights. Three intervenors—Dan, Hirsch, and Broslawsky—claimed that Harris' prosecution and the continued existence of the Act made them feel inhibited or uncertain about their own advocacy or teaching, though none had been indicted, arrested, or threatened with prosecution. The federal district court held the Act unconstitutional on its face and restrained further prosecution of Harris.

Issue

May a federal court enjoin a pending state criminal prosecution on the ground that the statute being enforced is facially unconstitutional under the First Amendment, where the prosecution appears to be a single good-faith prosecution and there is no showing of bad faith, harassment, or other extraordinary circumstances? Also, may unthreatened parties who merely feel inhibited by the statute and another person's prosecution obtain such relief?

Rule

Federal courts may not stay or enjoin pending state criminal proceedings except under special, extraordinary circumstances. Even irreparable injury is insufficient unless it is both great and immediate, and the usual injuries of defending a single good-faith criminal prosecution do not qualify; the possible facial unconstitutionality of the statute, including alleged vagueness or overbreadth under the First Amendment, does not by itself justify federal injunctive relief absent bad faith, harassment, or other unusual circumstances.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.
In Phoenix, Arizona, Naomi Reed is being prosecuted in state court under a state statute criminalizing certain public demonstrations near courthouses. She files suit in federal district court seeking to enjoin the prosecution, arguing the statute is facially overbroad under the First Amendment. There is no evidence the prosecutor acted in bad faith or singled her out for harassment.

Should the federal court grant the injunction?

Explanation. The majority held that federal courts ordinarily may not enjoin pending state criminal proceedings. The ordinary burden of defending a single prosecution is not the kind of irreparable injury that is both great and immediate, and the possible facial invalidity of the statute—even under the First Amendment—does not by itself justify an injunction absent bad faith, harassment, or other unusual circumstances.