The Supreme Court held that a federal court may enjoin the enforcement of an excessively vague state statute when there is evidence of bad faith and harassment in the enforcement of the statute.

According to the doctrine of abstention, federal courts normally do not intervene in state court proceedings until after they are finalized. James Dombrowski, leader of a civil rights organization in Louisiana, alleged that state officials were using broad antisubversion statutes as an excuse to harass and intimidate members of his organization. Citing the abstention doctrine, a federal court refused Dombrowski’s request for an injunction. By a 5-2 vote, however, the Supreme Court reversed the judgment. Justice William J. Brennan, Jr.’sBrennan, William J., Jr.;Dombrowski v. Pfister[Dombrowski v. Pfister] opinion for the majority argued that the intervention was justified because the statutes were “overly broad and vague regulations of expressions” and because the harassment and bad faith of state officials produced a “chilling effect” on free speech. In dissent, Justice John M. Harlan II argued that the Court’s departure from the traditional abstention doctrine was contrary to principles of federalism and comity.Abstention doctrine;Dombrowski v. Pfister[Dombrowski v. Pfister]Comity clause;Dombrowski v. Pfister[Dombrowski v. Pfister]

At first the Dombrowski decision led to a large number of lawsuits, but a narrow interpretation of the decision in Younger v. Harris[case]Younger v. Harris[Younger v. Harris] (1971) greatly limited the scope of federal intervention.

Chase, Samuel


Judicial review

Younger v. Harris