Cavanaugh v. Geballe, No. 21-571 (2d Cir. 2022)
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Plaintiff filed this federal action after a Connecticut probate court issued an order recognizing the validity of a state lien against plaintiff's interest in an estate. The district court applied the doctrine established in Younger v. Harris, 401 U.S. 37 (1971), and abstained from adjudicating plaintiff's suit because of the ongoing state probate proceedings.
The Second Circuit clarified that Younger abstention applies only to a narrow class of state civil proceedings. Civil probate proceedings are no more invulnerable to federal court interference than any other state civil proceedings, unless the state order at issue protects the State's administration of its judicial system or its process for compelling compliance with the judgments of its courts. The court concluded that the district court appears to have misunderstood the narrow scope of Younger abstention to extend to state probate proceedings that concern the validity of a lien. The court considered the Commissioner's remaining arguments and found them to be without merit. Therefore, the court vacated the district court's decision and remanded for further proceedings.
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