In Younger v. Harris, the Supreme Court declined to interfere in a state criminal prosecution by enjoining state proceedings based on a probably invalid statute. This deference reflects the Court's continuing effort to coordinate duplicative or potentially duplicative litigation. Coordination of duplicative litigation, however, has been developed in many contexts other than the protection of federal civil rights against state action. This Article examines the historical development of equitable intervention doctrines and discusses the tension between coordinating duplicative litigation and protecting state sovereignty. The Article concludes that federal relief should be denied when it may duplicate the work of state courts and is unlikely to free the citizen from oppression.
William H. Theis,
Younger v. Harris: Federalism in Context,
33 Hastings L.J. 103
Available at: https://repository.uchastings.edu/hastings_law_journal/vol33/iss1/2