| Venue: | SCOTUS |
| Facts: | The Hernandezes are accused of concealing assets while receiving public assistance, which is a crime in IL. |
| Posture: | IL files suit in state court, but this was a civil suit only, seeking just the return of the money, and attaching their property. No answer is filed, but the Hernandezes then file a suite in US district court, pruporting to represent a class of debtors whose property had been attached by the state without due process. The district court certifies the class. |
| Issue: | Should the court abstain, when there's no criminal prosecution, but there's a pending civil case? |
| Holding: | Yes, taking this case was an error-- reversed. |
| Rule: | The pendence of state court action calls for restraint, and the complaint should be dismissed un less there are circumstances warranting federal intervention, or state remedies are inadequate. |
| Reasoning: | There was a suit pending here in state court. And it involved important state policies. If the federal court takes this case, the state would be faced with the choice of engaging in duplicative litigation, risking a federal injunction, or interrupting its proceedings to wait on the federal court to decide its issue at some unknown future time. Also, the state wouldn't have the chance to construe its statute in a manner that's harmonious with federal rights. We don't want to eviscerate state courts this way. |
| Dicta: | Brennan (dissenting): The purpose of § 1983 was to allow federal
courts to resolve these issues without having to wait on state
courts. Why should a state plaintiff enjoy an advantage in its
own courts over a citizen defendant?
Stevens (dissenting): By the way, we're talking about state procedure here, not statute, so the Younger doctrine doesn't apply. |