Mar 31, 2009

Younger Doctrine and Federal Intervention into State Court Criminal Action

Safe Haven Sober Houses v. City of Boston, 517 F.Supp.2d 557 (D.Mass. 2007).
When Boston brought criminal proceedings against the owners and operators of homes for recovering alcoholics and drug users, those Defendants filed a preliminary injunction to stay the state criminal court proceedings. The Defendants argued that the court should analyze the motion under the traditional four-part test 1) likelihood of success on the merits 2) irreparable harm 3) balancing of the equities, and 4) the effect on the public interest of either the granting or denial of the injunction. The court analyzed the case under the Younger doctrine which prohibits a federal court from intervening in a state court criminal proceeding except under the following unusual circumstances: 1) "a statute that is 'flagrantly and patently violative of express constitutional prohibitions in every clause, sentence and paragraph, and in whatever manner and against whomever an effort might be made to apply it' (2) state prosecutions brought in bad faith without 'any expectation of securing valid convictions' or (3) when it 'plainly appears' that pursuing claims in pending state proceedings 'would not afford adequate protections.'" Id. at 561-62 (quoting Younger v. Harris, 401 U.S. 37 (1971))

The court summarily dismissed the first prong of the analysis and spent more time on the second. Relying on Dombrowski "the seminal bad faith prosecution case identified in Younger" the court recited the two-prong analysis for state prosecutions brought in bad faith: (1) "'a prosecution has been brought without reasonable expectation of abtaining a valid conviction;'and (2) the defendants cannot adequately assert their claims because of an unavailable or biased state forum." Safe Haven, F.Supp 2d at 562-63. Finding that the city was not harassing the housing providers as it was responding to the providers' violations of zoning and building regulations. The court found this prong inapplicable as well.

Further, the court elaborated on the third prong, the adequacy of state protections, as applicable "(1) when a state forum is biased or (2) when a state forum cannot provide a remedy." Id. at 566. The court found this prong inapplicable. The motion for the preliminary injunction was denied.

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