## Facts

- A Florida state attorney filed a civil nuisance action in Florida state court to close Robert Mitchum’s bookstore under state obscenity-related nuisance law.
- The state court issued a preliminary injunction that effectively shut down the bookstore.
- Mitchum sued state officials in federal court under 42 U.S.C. § 1983, alleging the nuisance statute’s application and the state-court injunction violated the First and Fourteenth Amendments.
- Mitchum sought declaratory relief and an injunction to stay the pending state-court proceedings.
- A single federal judge initially issued a temporary restraining order, but a three-judge district court dissolved it and denied further injunctive relief.
- The three-judge district court ruled the Anti-Injunction Act, 28 U.S.C. § 2283, barred any federal injunction against the ongoing state proceeding.
- Mitchum appealed directly to the U.S. Supreme Court from the three-judge court’s denial of injunctive relief.

## Issues

1. Whether 42 U.S.C. § 1983 falls within the “expressly authorized by Act of Congress” exception to the Anti-Injunction Act, 28 U.S.C. § 2283, permitting a federal court to enjoin a pending state-court proceeding.
2. Whether § 2283 is an absolute bar to federal injunctive relief in a § 1983 action seeking to stay state proceedings.

## Decision

- The Supreme Court reversed and remanded.
- The Court held that § 1983 is an “expressly authorized” Act of Congress within the meaning of § 2283’s exception.
- The three-judge district court erred by treating § 2283 as an absolute prohibition against enjoining a pending state proceeding in any § 1983 case.
- The Court emphasized that, even when § 2283 does not bar relief, federal courts must still apply principles of equity, comity, and federalism (including constraints associated with Younger-type restraint) in deciding whether an injunction should issue.

## Legal Principles

- The Anti-Injunction Act generally bars federal injunctions against state-court proceedings, subject to limited exceptions, including injunctions “expressly authorized by Act of Congress.”
- A statute may qualify as “expressly authorized” even without explicitly referencing § 2283 if the statute creates a federal right or equitable remedy that, to achieve its intended scope, may require staying a state proceeding.
- Section 1983, enacted to provide a federal equitable remedy against unconstitutional action under color of state law (including judicial action), qualifies for § 2283’s “expressly authorized” exception.
- Recognizing § 1983 within the § 2283 exception establishes federal power to enjoin certain state proceedings, but issuance of an injunction remains governed by equitable discretion and federalism-based restraint.

## Conclusion

The Court held that § 1983 suits are not categorically blocked by the Anti-Injunction Act because § 1983 falls within § 2283’s “expressly authorized” exception; however, federal courts must still apply equitable and federalism-based limits when deciding whether to enjoin an ongoing state-court action.


Mitchum v. Foster, 407 U.S. 225 (1972)