| Venue: | SCOTUS |
| Facts: | Mitchum had an adult bookstore, and the state ordered it closed as a nuisance. |
| Posture: | Suit in federal court for injunctive and declaratory relief under § 1983 (violation of 1A and 14A rights). A panel of judges says this is barred by the Anti-Injunction Act. |
| Issue: | Is § 1983 an expressly authorized exception to the Anti-Injunction Act, as required by Younger v. Harris? |
| Holding: | Yes. Reversed. |
| Rule: | The Anti-Injunction Act doesn't preclude injunctions in § 1983 claims. |
| Reasoning: | In order to qualify for the "expressly authorized" exception, a federal
law doens't have to contain an express reference to the Anti
Injunction Act. Instead, it just teeds to create a uniquely
federal right or remedy enforceable by a federal court whose
scope would be frustrated if injunctions could not issue.
§ 1983 was intended to enforce the provisions of 14A against state government, not just the legislature or the executive. Congress did this because it was convinced that the relationship between the states and the nation needed to change with respect to federally created rights. The fact that congress authorizes a "suit in equity" under § 1983 plainly indicates that injunctions are an option. |
| Dicta: | The whole idea of § 1983 was to interpose the federal courts between the states and the people to protect from unconstitutional action under state law. |