abstention doctrine

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The abstention doctrine is an authority that precludes federal courts from hearing cases within its jurisdictions, instead, giving state courts authority over the case. The policy behind this doctrine is rooted in federalism, and the interest of allowing state courts to adjudicate matters that are particular significance to the state or its laws. Conflicts surrounding abstention commonly arise out of constitutional challenges to state laws.  

The abstention doctrine can be further divided into various sub-doctrines, based on a number of Supreme Court cases that have expanded on when abstention is warranted. These cases include Railroad Commission of Texas v. Pullman Co., 312 U.S. 496 (1941); Younger v. Harris, 401 U.S. 37 (1971); Burford v. Sun Oil Co., 319 U.S. 315 (1943); Rooker v. Fidelity Trust, 263 U.S. 413 (1923); and District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983)

The Pullman Doctrine 

The Pullman Doctrine states that federal courts should exercise its discretion to stay from a case, where constitutional considerations are at play, when state court proceedings can resolve the issue. The case involved a challenge to a Texas law that implicated violations to the Fourteenth Amendment. However, the Supreme Court stated that the Texas Supreme Court held ultimate authority on interpreting the state law, and as a result, the district court should "restrain their authority because of 'scrupulous regard for the rightful independence of state governments' and for the smooth working of the federal judiciary." 

The Younger Doctrine 

Abstention under Younger holds that federal courts should abstain from cases that are pending in state proceedings. The facts of Younger involved a criminal defendant that challenged the state (California) criminal statute for which he was indicted. While the defendant's criminal case was pending in the state, he challenged the constitutionality of the criminal statute in federal district court, obtaining a favorable holding. Still, the Supreme Court reversed the district court's holding, stating that states have a right to be free from federal interference with state criminal prosecutions brought in good faith. 

Although Younger was decided in the context of criminal proceedings, the supreme court in Exxon mobile corp. v. Saudi Basic Industries Corp., 544 U.S. 280 (2005) expanded Younger and held that when there is parallel litigation in state and federal courts, the federal court may be bound to recognize the preclusive effects of a state-court judgment. Additionally, the Supreme Court further held in Middlesex County Ethics Committee v. Garden State Bar Ass'n, 457 U.S. 423 (1982) that Younger is fully applicable to noncriminal judicial proceedings when important state interests are involved. For example, the Supreme Court found a state's regulation of its licensed attorneys to be an important interest in Middlesex.  

However, there are also exceptions to the Younger doctrine. Notably, it has been held that federal courts may exercise authority over a state proceeding where (1) the state brought the criminal proceeding in bad faith and (i.e., brought as a means of harassing the defendant); (2) the statute challenged is patently unconstitutional; or (3) the state forum's is incompetent to adjudicate because of, for example, bias. 

The Burford Doctrine

Abstention under Burford directs federal courts to refuse cases where state agency action is involved. Instead, federal courts should defer to state courts to review the state's agencies. The court held that "review of the [state agency's] decisions in state courts is expeditious and adequate," and that out of respect should be given to independence of state affairs. Indeed "[c]onflicts in the interpretation of state law, dangerous to the success of state policies, are almost certain to result from the intervention of the lower federal courts." 

The Rooker-Feldman Doctrine 

Lastly, the Rooker-Feldman doctrine held that while lower federal courts may review the constitutionality of state-promulgated statutes and rules, they may not review holdings of the state's supreme court pertaining to those policies. Rather, that authority is exclusively reserved for the Supreme Court of the United States. The court in Feldman, which dealt with the challenges to the District of Columbia's bar-admission policies illustrated this distinction. Specifically, the Supreme Court stated that the district court had jurisdiction over general challenges to the state's bar rules, promulgated in non-judicial proceedings and that do not require review of a final state court judgment. However, only the Supreme Court of the United States holds jurisdiction over challenges to matters that were intertwined with the D.C. Appellate Court's decisions in judicial proceedings. 

[Last updated in December of 2021 by the Wex Definitions Team]