Trainor v. Hernandez
Annotate this Case
431 U.S. 434 (1977)
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U.S. Supreme Court
Trainor v. Hernandez, 431 U.S. 434 (1977)
Trainor v. Hernandez
Argued January 18, 1977
Decided May 31, 1977
431 U.S. 434
Rather than charging appellees with the crime of fraudulently concealing assets while applying for and receiving public assistance, the Illinois Department of Public Aid (IDPA) brought a civil action against appellees in state court seeking only a return of the welfare payments alleged to have been wrongfully received, and as part of the action a writ of attachment was issued and executed pursuant to the Illinois Attachment Act against appellees' property without notice or hearing. Instead of seeking a prompt hearing in the state court or moving there to quash the attachment on federal constitutional grounds, appellees filed suit against appellant IDPA officials in Federal District Court, alleging that the Attachment Act was unconstitutional in that it provided for deprivation of debtors' property without due process of law, and seeking, inter alia, return of the attached property. Declining to dismiss the complaint under the doctrine of Younger v. Harris, 401 U. S. 37, and Huffman v. Pursue, Ltd., 420 U. S. 592, a three-judge court held the Act unconstitutional and issued an injunction directing return of appellees' attached property.
Held: The District Court should have dismissed appellees' complaint under Younger, supra, and Huffman, supra, unless their state remedies were inadequate to litigate their federal due process claim, since the injunction asked for and issued by the court interfered with Illinois' efforts to utilize the Attachment Act as an integral part of the State's enforcement action. Pp. 431 U. S. 440-447.
(a) The principles of Younger and Huffman are broad enough to apply to interference by a federal court with an ongoing civil enforcement action such as this, brought by the State in its sovereign capacity. Pp. 431 U. S. 443-444.
(b) For the federal court to have proceeded with the case rather than remitting appellees to their remedies in the pending state suit confronts the State with the choice of engaging in duplicative litigation, thereby risking a temporary federal injunction, or of interrupting its enforcement proceedings pending the federal court's decision at some unknown time in the future; and forecloses the state court's opportunity
to construe the challenged statute in the face of the federal constitutional challenges that would also be pending for decision before it. P. 431 U. S. 445.
(c) There was no basis for the District Court's proceeding to judgment on the ground that extraordinary circumstances warranted federal interference. There is no suggestion that the pending state action was brought in bad faith or to harass appellees, and no basis for finding that the Attachment Act violated
"express constitutional provisions in every clause, sentence and paragraph and in whatever manner and against whomever an effort might be made to apply it."
Pp. 431 U. S. 446-447.
405 F Supp. 757, reversed and remanded.
WHITE, J., delivered the opinion of the Court, in which BURGER, C.J., and BLACKMUN, POWELL, and REHNQUIST, JJ., joined. BLACKMUN, J., filed a concurring opinion, post, p. 431 U. S. 448. BRENNAN, J., filed a dissenting opinion, in which MARSHALL, J., joined, post, p. 431 U. S. 450. STEWART, J., filed a dissenting statement, post, p. 431 U. S. 448. STEVENS, J., filed a dissenting opinion, post, p. 431 U. S. 460.