What is the test for a federal court to enjoin a state court proceeding?
The following excerpt is from ET v. George, 681 F. Supp.2d 1151 (E.D. Cal. 2010):
It is within the context of this foundational concept of comity, which strikes at the heart of the country's governing principles, that the court must view plaintiffs' serious claims. The court is cognizant of the potential hardships inflicted upon one of society's most vulnerable populations if plaintiff's claims are true. The court is equally cognizant of the profound consequential principles of federalism implicated by this case. Accordingly, it is with careful attention to these two significant but conflicting interests that the court undertakes its analysis of justiciability pursuant to its equitable discretion and under the principles set forth by Younger v. Harris and its progeny.2
Principles of equity, comity, and federalism preclude equitable intervention when a federal court is asked to enjoin a
[681 F. Supp.2d 1162]
state court proceeding. O'Shea v. Littleton, 414 U.S. 488, 499-500, 94 S.Ct. 669, 38 L.Ed.2d 674 (1974). The doctrine of equity jurisprudence provides that a "court of equity should not act . . . when the moving party has an adequate remedy at law and will not suffer irreparable injury if denied equitable relief." Id. at 499, 94 S.Ct. 669.[681 F. Supp.2d 1162]
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