## Facts

- Ohio officials brought a state civil public-nuisance action against an adult movie theater under a statute treating places exhibiting obscene films as nuisances.
- The statute authorized up to one year’s closure of a place found to be a nuisance and permitted seizure and sale of personal property used in the nuisance.
- After finding the theater had exhibited obscene films, the Ohio trial court ordered the theater closed for one year and ordered seizure and sale of certain property.
- Rather than appealing through Ohio’s appellate courts, the theater operator filed a federal action under 42 U.S.C. § 1983 seeking declaratory and injunctive relief against enforcement of the state judgment and challenging the statute under the First and Fourteenth Amendments.
- The federal district court declared the statute unconstitutional on First Amendment grounds and enjoined execution of the closure order as to films not previously adjudicated obscene.
- The Supreme Court reviewed whether federal intervention was barred by Younger abstention principles given the state enforcement proceeding and available state appellate remedies.

## Issues

1. Whether Younger abstention extends to a state civil nuisance action brought by state officials that functions similarly to a criminal prosecution.
2. Whether a party may bypass available state appellate review of an adverse state trial judgment by seeking federal declaratory and injunctive relief under § 1983, absent a recognized Younger exception.

## Decision

- The Court held that Younger principles apply to this state civil nuisance proceeding because it was closely related to criminal enforcement and carried sanctions resembling criminal penalties.
- The Court ruled the federal district court should not have reached the merits or enjoined enforcement of the state judgment unless the theater operator established a narrow Younger exception.
- The Court found no adequate showing of bad faith, harassment, or a statute that is flagrantly and patently unconstitutional.
- The Court vacated the federal judgment and remanded for proceedings consistent with Younger abstention.

## Legal Principles

- Younger abstention can bar federal declaratory or injunctive relief interfering with certain state civil enforcement actions, particularly those initiated by state officials and comparable to criminal prosecutions.
- For Younger purposes, a state proceeding may be treated as “ongoing” when state appellate remedies remain available and have not been pursued.
- Federal intervention is permitted only under limited exceptions, including state action brought in bad faith or for harassment, or a statute that is facially and flagrantly unconstitutional.
- A federal district court generally should not serve as an alternative forum to relitigate or effectively nullify a state trial court result when adequate state appellate review exists.

## Conclusion

The Court required federal courts to abstain under Younger from enjoining or declaring invalid a state-court nuisance judgment in a quasi-criminal civil enforcement action where state appellate review remained available, absent bad faith, harassment, or a flagrantly unconstitutional statute.


Huffman v. Pursue, Ltd., 420 U.S. 592 (1975)