The recent United States Supreme Court decision of Younger v. Harris along with its companion cases represent the most significant development in the area of federal-state court relations since the Court decided Dombrowski v. Pfister in 1965. Dombrowski created grave doubts over the continued validity of the long established public policy against federal court interference with state court proceedings. Civil libertarians were quick to seize upon the broad assertions in that case as support for their efforts toward expanding the concept of federal court intervention in state criminal prosecutions. Though the Court was given the opportunity to reconcile the conflicting interpretations over the significance of Dombrowski, it failed to do so and basic doubts as to the true dimensions of that decision remained unanswered until the Court decided Younger v. Harris and its companion cases in February, 1971. Because Younger was expressly limited in its application to pending state criminal prosecutions, this Comment in attempting to assess the importance of that decision will be confined solely to the developments in that area of the law.
Federal Court Intervention in Pending State Criminal Prosecutions- The Significance of Younger v. Harris,
U. Rich. L. Rev.
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