## Facts

- John Harris, Jr. was indicted in California state court under the California Criminal Syndicalism Act.
- Harris filed a federal § 1983 action seeking to enjoin the Los Angeles County District Attorney from continuing the pending state prosecution, alleging the statute was facially unconstitutional and chilled First Amendment activity.
- Jim Dan, Diane Hirsch, and Farrel Broslawsky intervened, claiming the statute and Harris’s prosecution inhibited their speech and (for Broslawsky) teaching, though they were not charged or threatened with prosecution.
- A three-judge federal district court declared the statute void for vagueness and overbreadth and enjoined the ongoing state prosecution.
- The District Attorney appealed directly to the Supreme Court; the Court resolved the case on equitable and federalism grounds without deciding the statute’s constitutionality.

## Issues

1. Whether a federal court may enjoin a pending state criminal prosecution based on the alleged unconstitutionality of the underlying statute, absent bad faith, harassment, or other extraordinary circumstances showing great and immediate irreparable injury.
2. Whether intervenors not indicted, arrested, or threatened with prosecution may obtain federal injunctive relief based on alleged chilling effects from a statute’s existence and another person’s prosecution.

## Decision

- The Supreme Court reversed the injunction against the pending state prosecution.
- Federal courts may not enjoin ongoing state criminal prosecutions except in extraordinary circumstances where irreparable harm to federally protected rights is both great and immediate.
- The burden and stress of defending a single prosecution, even under a statute alleged to be unconstitutional, is not irreparable injury justifying federal equitable relief.
- Dan, Hirsch, and Broslawsky lacked a basis for equitable relief because their asserted injuries were speculative; they faced no indictment, arrest, or threat of prosecution.
- The Court declined to adjudicate the constitutionality of the Criminal Syndicalism Act.

## Legal Principles

- Principles of equity and comity require federal courts to refrain from interfering with state criminal prosecutions when the defendant can raise constitutional defenses in the state proceeding and no extraordinary circumstances exist.
- A statute’s alleged facial invalidity does not, by itself, justify a federal injunction against a pending state prosecution.
- Federal intervention may be warranted where prosecutions are brought in bad faith, as harassment, or under other exceptional conditions creating great and immediate irreparable harm that cannot be remedied in state court.
- Speculative or conjectural chilling effects on third parties who are not prosecuted or threatened with prosecution do not establish a sufficient basis for federal equitable jurisdiction.
- State courts are presumed competent and obligated to adjudicate federal constitutional claims in the course of state criminal proceedings.

## Conclusion

The Court held that federal equitable power generally may not be used to halt a pending state criminal prosecution, absent bad faith, harassment, or comparable extraordinary circumstances causing great and immediate irreparable injury, and it rejected standing-equivalent claims of speculative chill by unthreatened intervenors, establishing the core rule associated with Younger abstention.


Younger v. Harris, 401 U.S. 37 (1971)