Deakins v. Monaghan

484 U. S. 193

January 12, 1988

During grand jury proceedings, numerous record of a construction company were seized by the police. The company filed a 1983 claim in federal court for injunctive and monetary relief. The federal court dismissed these claims, citing the Younger rule that federal courts must not intervene in state court proceedings. Eventually, some of the issues in the state court proceedings got settled, and the equitable relief question was effectively mooted. The construction company agreed to drop the equitable claims from their federal action.

Unanimously, the Supreme Court allowed the equitable claims to be dropped, but ordered that the federal courts grant a stay on the monetary relief claims, to allow for litigation on that question later. Blackmun found that the equitable issues were indeed moot, and vacated any other federal treatment of that question. With regard to the request for damages, Blackmun found that this relief was only available in federal courts, and accordingly the company must have a chance to make its case. A stay would preserve this right, while allowing the state courts to finish their business uninterrupted.

White, joined by O’Connor, concurred in judgment (but confusing labeled his opinion a ‘concurrence’). He objected to the majority opinion’s tacit implication that a federal court could not only issue a stay, but could alternatively go ahead and determine the damages question immediately. Because determining whether damages were warranted would necessarily also involve some determination of state court issues, White thought that Younger abstention required that only stays could be issued. While the Court’s ruling was sound, I’m just 15 cases into the term, and I’m already sick of justiciability decisions. Hopefully, they’ll get to the more meaty cases very soon.

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