Mitchum v. Foster
Citation and Court
407 U.S. 225 (1972) — Supreme Court of the United States
Facts
Foster operated a bookstore in Florida that was the subject of state court proceedings seeking to declare it a public nuisance and enjoin its operation. Foster sought a federal injunction against the state court proceedings under 42 U.S.C. § 1983, alleging First Amendment violations. The district court dismissed, concluding that the Anti-Injunction Act, 28 U.S.C. § 2283, barred the federal injunction.
Issue
Whether 42 U.S.C. § 1983 is an “expressly authorized” exception to the Anti-Injunction Act, permitting a federal court to enjoin pending state court proceedings.
Holding
Yes. Section 1983 is an expressly authorized exception to the Anti-Injunction Act; a federal court may therefore enjoin pending state court proceedings to protect or effectuate federal civil rights when § 1983 provides the basis for relief.
Rule / Doctrine
The Anti-Injunction Act bars federal injunctions against state court proceedings except where “expressly authorized by Act of Congress.” An explicit congressional authorization is not required; it is enough that the federal statute creates a federal right or remedy so incompatible with state court interference that Congress must have intended to allow federal injunctions to protect it.
Significance
Mitchum is essential for understanding the interplay between § 1983 and the Anti-Injunction Act. Combined with Younger v. Harris (1971), it creates a nuanced framework: § 1983 technically allows federal injunctions against state proceedings, but Younger abstention as a matter of comity still generally requires federal courts to refrain from enjoining pending state criminal prosecutions absent extraordinary circumstances.