Dombrowski v. Pfister
Encyclopedia
Dombrowski v. Pfister 380 U.S. 479 (1965) was a landmark Supreme Court
case brought forth by Dr. James Dombrowski along with William Kunstler
, founder of the Center for Constitutional Rights
, against the governor of Louisiana
, law enforcement officers, and the chairperson of the state's Legislative Joint Committee on Un-American Activities for prosecuting or threatening to prosecute his organization under several state subversion statutes.
However, a three-judge Federal district court dismissed the claim, stating that Dombrowski had failed to show evidence of irreparable damage and asserted the abstention doctrine
, stating that State Courts had the right to refrain from ruling in Constitutional questions.
Represented by attorney and civil rights leader Arthur Kinoy
, Dombrowski appealed the case directly to the Supreme Court under then-operational procedures. The Court overturned the earlier dismissal, making note of the "chilling effect" the ruling below would have had on First amendment rights.
(1971) that there existed a "national policy forbidding federal courts to stay or enjoin pending state court proceedings except under special circumstances." The Court specifically distinguished Dombrowski, stating that the holding of that case was merely a limited exception to the general rule forbidding the enjoining of state court proceedings. The Court stated that it was appropriate for a federal claim to go forward in Dombrowski because the consistent pattern of bad faith prosecutions denied the claimant the opportunity to pursue his constitutional challenge to anti-subversion statutes in state court. Moreover, the Younger Court asserted that the bare existence of a chilling effect as in Dombrowski was insufficient to justify enjoining state proceedings, without more.
The Supreme Court in Younger conceded that bad faith prosecution like the pattern in Dombrowski would justify a federal court in issuing an injunction against state proceedings. However, since the announcement of Younger in 1971, the Supreme Court has never found an instance of alleged bad faith prosecution to, in fact, meet the requirements of this exception to the no-injunction rule. As commentator Erwin Chemerinsky
states, the bad-faith prosecution exception seems narrowly limited to facts like those in Dombrowski. Other scholars have even asserted that the possible range of cases which would fit the Dombrowski model and allow an exception to the no-injunction rule is so limited as to be an "empty universe."
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case brought forth by Dr. James Dombrowski along with William Kunstler
William Kunstler
William Moses Kunstler was an American self-described "radical lawyer" and civil rights activist, known for his controversial clients...
, founder of the Center for Constitutional Rights
Center for Constitutional Rights
Al Odah v. United States:Al Odah is the latest in a series of habeas corpus petitions on behalf of people imprisoned at the Guantanamo Bay detention center. The case challenges the Military Commissions system’s suitability as a habeas corpus substitute and the legality, in general, of detention at...
, against the governor of Louisiana
Louisiana
Louisiana is a state located in the southern region of the United States of America. Its capital is Baton Rouge and largest city is New Orleans. Louisiana is the only state in the U.S. with political subdivisions termed parishes, which are local governments equivalent to counties...
, law enforcement officers, and the chairperson of the state's Legislative Joint Committee on Un-American Activities for prosecuting or threatening to prosecute his organization under several state subversion statutes.
Background
Dombrowski alleged that members of his organization, the Southern Conference Educational Fund, were subjected to continuous harassment, including arrests without intent to prosecute, and seizures of necessary internal documents. Furthermore, the State was threatening to use anti-subversion statutes to prosecute the organization, which was a group of Southern liberals dedicated to fighting for civil rights for Blacks in the South.Decision
The case was brought forth by Dombrowski after he was arrested and his offices were raided by authorities in October 1963. Dombrowski demanded all seized materials to be returned to him and $500,000 be paid in damages resulting from the arrest and search-and-seizure.However, a three-judge Federal district court dismissed the claim, stating that Dombrowski had failed to show evidence of irreparable damage and asserted the abstention doctrine
Abstention doctrine
An abstention doctrine is any of several doctrines that a court of law in the United States of America might apply to refuse to hear a case, when hearing the case would potentially intrude upon the powers of another court...
, stating that State Courts had the right to refrain from ruling in Constitutional questions.
Represented by attorney and civil rights leader Arthur Kinoy
Arthur Kinoy
Arthur Kinoy , was an attorney and progressive civil rights leader who became a professor of law at the Rutgers School of Law—Newark. He was one of the founders of the Center for Constitutional Rights and successfully argued before the Supreme Court of the United States.-Education:Kinoy was born on...
, Dombrowski appealed the case directly to the Supreme Court under then-operational procedures. The Court overturned the earlier dismissal, making note of the "chilling effect" the ruling below would have had on First amendment rights.
Status as precedent
Several years after the Dombrowski, the Supreme Court decided in Younger v. HarrisYounger v. Harris
Younger v. Harris, 401 U.S. 37 , was a case in which the United States Supreme Court held that United States federal courts were required to abstain from hearing any civil rights tort claims brought by a person who is currently being prosecuted for a matter arising from that claim.-Facts:A...
(1971) that there existed a "national policy forbidding federal courts to stay or enjoin pending state court proceedings except under special circumstances." The Court specifically distinguished Dombrowski, stating that the holding of that case was merely a limited exception to the general rule forbidding the enjoining of state court proceedings. The Court stated that it was appropriate for a federal claim to go forward in Dombrowski because the consistent pattern of bad faith prosecutions denied the claimant the opportunity to pursue his constitutional challenge to anti-subversion statutes in state court. Moreover, the Younger Court asserted that the bare existence of a chilling effect as in Dombrowski was insufficient to justify enjoining state proceedings, without more.
The Supreme Court in Younger conceded that bad faith prosecution like the pattern in Dombrowski would justify a federal court in issuing an injunction against state proceedings. However, since the announcement of Younger in 1971, the Supreme Court has never found an instance of alleged bad faith prosecution to, in fact, meet the requirements of this exception to the no-injunction rule. As commentator Erwin Chemerinsky
Erwin Chemerinsky
Erwin Chemerinsky is an American lawyer and law professor. He is a prominent scholar in United States constitutional law and federal civil procedure...
states, the bad-faith prosecution exception seems narrowly limited to facts like those in Dombrowski. Other scholars have even asserted that the possible range of cases which would fit the Dombrowski model and allow an exception to the no-injunction rule is so limited as to be an "empty universe."