Kugler v. Helfant
Annotate this Case
421 U.S. 117 (1975)
U.S. Supreme Court
Kugler v. Helfant, 421 U.S. 117 (1975)
Kugler v. Helfant
Argued March 25, 1975
Decided April 28, 1975*
421 U.S. 117
One Helfant, who was a Municipal Court judge and a member of the New Jersey bar, brought this action in District Court permanently to enjoin the State Attorney General and other officials from proceeding with the prosecution of an indictment of Helfant, which had grown out of grand jury testimony that he had given as a result of assertedly collusive coercion by a State Deputy Attorney General and members of the New Jersey Supreme Court, whose significant involvement allegedly made it impossible for Helfant to receive a fair trial in the New Jersey state courts. The District Court issued an order dismissing the complaint, on the basis of Younger v. Harris, 401 U. S. 37, which held that, unless "extraordinary circumstances" exist in which irreparable injury can be shown even in the absence of bad faith and harassment, a federal court must not intervene by way of granting injunctive or declaratory relief against a state criminal prosecution. The Court of Appeals, though holding that a permanent injunction of the state criminal prosecution would be inappropriate, reversed the order and remanded the case for an evidentiary hearing on Helfant's coercion charge and for entry of a declaratory judgment, based upon that hearing, on the question whether his grand jury testimony was admissible in the state criminal trial. Helfant claims that federal judicial intervention is warranted under Younger's "extraordinary circumstances" exception because of the assertedly coercive involvement of the members of the New Jersey Supreme Court, who have formidable supervisory and administrative powers over the state court system.
1. Helfant's claim that he cannot obtain a fair hearing in the state courts is without merit, and the facts he alleges do not bring this matter within any exception to the Younger rule so as to warrant the granting of injunctive relief against the state criminal prosecution. Pp. 421 U. S. 123-129.
(a) The New Jersey judicial system safeguards a defendant like Helfant against denial of due process of law in the state trial or appellate process by providing that a defendant can disqualify a particular judge from participating in his case, mandating disqualification of an appellate judge whose participation might reasonably lead counsel to believe he was biased, and providing for temporary assignment of substitute Justices where a Supreme Court quorum is lacking. Pp. 421 U. S. 126-128.
(b) Four of the six members (including the then Chief Justice) of the New Jersey Supreme Court who participated in the alleged coercion are no longer on that court, and, of the two remaining members, only one was active in the conduct complained of. P. 421 U. S. 128.
(c) The Chief Justice is the administrative head of the New Jersey court system, and the incumbent played no part in the allegedly coercive conduct. P. 421 U. S. 128.
2. Federal courts should refuse to intervene in state criminal proceedings to suppress the use of evidence even when claimed to have been unlawfully obtained, Stefanelli v. Minard, 342 U. S. 117; Perez v. Ledesma, 401 U. S. 82, and the declaratory judgment procedure ordered by the Court of Appeals would contravene the basic policy against federal interference with state prosecutions as much as would the granting of the injunctive relief sought by Helfant. Pp. 421 U. S. 129-131.
500 F.2d 1188, vacated and remanded.
STEWART, J., delivered the opinion of the Court, in which BURGER, C.J., and WHITE, MARSHALL, BLACKMUN, POWELL, and REHNQUIST, JJ., joined. DOUGLAS, J., took no part in the consideration or decision of the cases. BRENNAN, J., took no part in the decision of the cases.