## Facts

- South Carolina criminal gambling statutes prohibited certain “games of chance” devices and authorized seizure of prohibited machines.
- Jimmy Martin and Lucky Strike, LLC operated video-poker machines in South Carolina.
- The plaintiffs alleged the statutes were unconstitutionally vague because they failed to provide fair notice of what devices were prohibited.
- The plaintiffs also alleged the statutes permitted arbitrary and discriminatory enforcement.
- The plaintiffs sought declaratory and injunctive relief against state officials in federal court under federal constitutional theories (due process and equal protection).
- The district court dismissed the action on Burford abstention grounds, reasoning federal adjudication would interfere with state regulation of gambling.
- The plaintiffs appealed.

## Issues

1. Whether Burford abstention permitted a federal court to dismiss a federal constitutional challenge to state gambling-device criminal statutes.
2. Whether the challenged scheme involved the type of specialized, unified state administrative and judicial review structure that justifies Burford abstention.
3. Whether the possibility that state courts could adjudicate the federal claims, standing alone, supported abstention.

## Decision

- The Fourth Circuit reversed the district court’s dismissal and remanded.
- Burford abstention did not apply because the case presented direct federal constitutional claims rather than a dispute requiring deference to a specialized state administrative regime.
- The gambling-device provisions functioned as ordinary criminal statutes enforceable in ordinary state courts, not as part of a complex administrative system with centralized review comparable to Burford.
- The federal court’s exercise of jurisdiction over facial or as-applied federal constitutional challenges to state statutes did not pose the type of disruption to state policymaking that Burford addresses.
- The adequacy of state courts to decide federal issues was not, by itself, a sufficient reason to decline federal jurisdiction.

## Legal Principles

- Federal courts have a strong obligation to exercise jurisdiction conferred by Congress; abstention is an exceptional departure from that duty.
- Burford abstention is narrowly limited to circumstances where federal review would disrupt a state’s efforts to maintain a coherent policy through a complex administrative scheme with specialized, unified state-court review.
- A federal constitutional challenge to the validity of state statutes, seeking prospective relief against state officials, ordinarily falls within core federal-question jurisdiction and is not displaced by general state regulatory interests.
- The mere availability of state forums competent to decide federal questions does not establish the predicate for Burford abstention.

## Conclusion

The Fourth Circuit held that the district court improperly abstained under Burford because the plaintiffs’ due process and equal protection challenges to South Carolina gambling-device statutes did not implicate a specialized state administrative review system or present the kind of disruption Burford is designed to prevent, so the federal action had to proceed on the merits.


Martin v. Stewart, 499 F.3d 360 (4th Cir. 2007)