## Facts

- Illinois officials alleged Juan and Maria Hernandez wrongfully received public assistance by concealing assets.
- Instead of pursuing criminal charges, the Illinois Department of Public Aid filed a state-court civil action to recover the alleged overpayments.
- In that action, the State obtained a writ of attachment under the Illinois Attachment Act, executed without prior notice or hearing, attaching the Hernandezes’ property (including a credit union account).
- The Hernandezes did not seek state-court relief (such as moving to quash the attachment or requesting a prompt hearing) on federal constitutional grounds.
- The Hernandezes filed a federal § 1983 class action seeking declaratory and injunctive relief, arguing the Attachment Act violated due process by permitting deprivation of property without prior notice or hearing.
- A three-judge federal district court reached the merits, held the Attachment Act unconstitutional, and enjoined the State officials, ordering return of the attached property while the state civil action was pending.

## Issues

1. Whether a federal court must abstain under Younger principles from granting injunctive or declaratory relief that interferes with an ongoing state civil enforcement action brought by the State in its sovereign capacity.
2. Whether abstention is inappropriate because state procedures are inadequate to provide a full and fair opportunity to litigate the federal due process challenge to the attachment process.
3. Whether any exception to abstention applies, including bad faith, harassment, or other extraordinary circumstances.

## Decision

- The Supreme Court reversed the federal district court.
- The Court held the § 1983 action should have been dismissed under Younger and Huffman because it interfered with an ongoing state civil enforcement proceeding.
- The Court found no showing that Illinois courts were an inadequate forum for the due process claim.
- The Court found no basis for an exception to abstention, including bad faith, harassment, or a patently unconstitutional statute.

## Legal Principles

- Younger abstention applies not only to criminal prosecutions but also to state civil enforcement actions brought by the State in its sovereign capacity.
- Federal courts ordinarily may not enjoin or declare invalid state procedures in a pending state enforcement case when the federal claimant can raise constitutional objections in the state proceeding.
- Abstention is generally required when (1) a state proceeding is ongoing, (2) the proceeding implicates important state interests, and (3) the state forum provides an adequate opportunity to raise federal constitutional claims.
- Exceptions to abstention require a showing of bad faith, harassment, or other extraordinary circumstances; mere allegations of constitutional infirmity in the challenged procedure are insufficient when state remedies are available.

## Conclusion

The Court required federal courts to abstain from interfering with Illinois’ ongoing civil enforcement action to recoup allegedly wrongful welfare payments, because the Hernandezes could raise their due process challenge in state court and no extraordinary circumstances justified federal injunctive relief.


Trainor v. Hernandez, 431 U.S. 434 (1977)