Dombrowski v. Pfister
|Dombrowski v. Pfister|
|Argued January 25, 1965|
Decided April 26, 1965
|Full case name||Dombrowski, et al. v. Pfister, Chairman, Joint Legislative Committee on Un-American Activities of the Louisiana Legislature, et al.|
|Citations||380 U.S. 479 (more)|
|Majority||Brennan, joined by Warren, Douglas, White, Goldberg|
|Dissent||Harlan, joined by Clark|
|Black and Stewart took no part in the consideration or decision of the case.|
|U.S. Const. amend. I|
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Dombrowski v. Pfister, 380 U.S. 479 (1965), was a landmark United States Supreme Court case brought forth by Dr. James Dombrowski along with William Kunstler, founder of the Center for Constitutional Rights, against the governor of Louisiana, law enforcement officers, and the chairperson of the state's Legislative Joint Committee on Un-American Activities for prosecuting or threatening to prosecute his organization under several state subversion statutes.
Dombrowski alleged that members of his organization, the Southern Conference Educational Fund, a group of Southern liberals dedicated to fighting for civil rights for Blacks in the South, were subjected to continuous harassment, including arrests without intent to prosecute, and seizures of necessary internal documents. Furthermore, the State was threatening to use anti-subversion statutes to prosecute the organization.
The case was brought forth by Dombrowski after he was arrested and his offices were raided by authorities in October 1963. Dombrowski demanded all seized materials to be returned to him and $500,000 be paid in damages resulting from the arrest and search-and-seizure.
However, a three-judge Federal district court dismissed the claim, stating that Dombrowski had failed to show evidence of irreparable damage and asserted the abstention doctrine, stating that State Courts had the right to refrain from ruling in Constitutional questions.
Represented by attorney and civil rights leader Arthur Kinoy, Dombrowski appealed the case directly to the Supreme Court under then-operational procedures. The Court overturned the earlier dismissal, making note of the "chilling effect" the ruling below would have had on First amendment rights.
Status as precedent
Several years after the Dombrowski, the Supreme Court decided in Younger v. Harris (1971) that there existed a "national policy forbidding federal courts to stay or enjoin pending state court proceedings except under special circumstances." The Court specifically distinguished Dombrowski, stating that the holding of that case was merely a limited exception to the general rule forbidding the enjoining of state court proceedings. The Court stated that it was appropriate for a federal claim to go forward in Dombrowski because the consistent pattern of bad faith prosecutions denied the claimant the opportunity to pursue his constitutional challenge to anti-subversion statutes in state court. Moreover, the Younger Court asserted that the bare existence of a chilling effect as in Dombrowski was insufficient to justify enjoining state proceedings, without more.
The Supreme Court in Younger conceded that bad faith prosecution like the pattern in Dombrowski would justify a federal court in issuing an injunction against state proceedings. However, since the announcement of Younger in 1971, the Supreme Court has never found an instance of alleged bad faith prosecution to, in fact, meet the requirements of this exception to the no-injunction rule. As commentator Erwin Chemerinsky states, the bad-faith prosecution exception seems narrowly limited to facts like those in Dombrowski. Other scholars have even asserted that the possible range of cases which would fit the Dombrowski model and allow an exception to the no-injunction rule is so limited as to be an "empty universe."
- Erwin Chemerinsky, Federal Jurisdiction (5th ed. 2007), Aspen Publishers, p. 826-27
- Chemerinsky, p. 826-27
- Chemerinsky, p. 859
- Chemerinsky, p. 860
- Chemerinsky, p. 859-60