Younger Doctrine Used to Dismiss Federal Court Claims

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Recently, in Berg v. Berg, et al., No. 19-CV-2676 (ECT/KMM), 2020 WL 490965 (D. Minn. Jan. 30, 2020), a dissatisfied party to a state court marital dissolution brought claims in federal court not only against his spouse, but also against the receiver and the Special Master who had ruled against him. Lommen Abdo successfully defended the Special Master and obtained dismissal of the federal court action based on Younger abstention.

Generally, the presence of federal jurisdiction compels its exercise, and the mere presence of concurrent state court litigation involving the same parties or issues does not justify its abdication. Colorado River Water Conservation Dist. v. United States, 424 U.S. 800, 813-14, 817-18 (1976). But the Younger doctrine is an exception. Based on Younger v. Harris, 401 U.S. 37 (1971), it directs federal courts to abstain from granting injunctive or declaratory relief that would interfere with pending judicial proceedings. Night Clubs, Inc. v. City of Fort Smith, Ark., 163 F.3d 475, 481 (8th Cir. 1998). It applies when there is (1) a related ongoing state court proceeding, (2) an important state interest, and (3) an adequate opportunity to raise the federal questions in the state proceeding. Fuller v. Ulland, 76 F.3d 957, 959 (8th Cir. 1996).

In Berg, the plaintiff argued his constitutional rights were violated when he was held in contempt and jailed for failing to abide by the court’s orders. He sought declaratory and injunctive relief essentially to undo the state court’s orders. The defense argued the federal court should abstain from exercising jurisdiction under Younger because Minnesota has an exceptional interest in its contempt process and any complaints with the contempt process should be reviewed by the Minnesota appellate courts, without interference from the federal district court.

The federal court agreed with the defense and dismissed the case, noting that the state court proceeding was ongoing and that the state court’s contempt power was an important state interest with which the federal court should not interfere. It also recognized that the plaintiff had the ability to raise the federal issues in state court and had in fact already done so by petitioning for a writ of prohibition from the Minnesota Court of Appeals. The federal court declined to grant a stay pending resolution of the state action and instead dismissed the case in its entirety.