Younger doctrine (California) · Go Syfert
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Younger doctrine in California

7 California opinions name it 2 courts 1980–2025 2 in the last five years

The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (8)

CaseFollowedCited
Middlesex County Ethics Committee v. Garden State Bar Ass'ngreen
scotus · 1982 · cited in 2 California opinions naming this issue, 2006–2010
2 sentences

2010The court also rested its decision on abstention under the Younger doctrine (Younger v. Harris (1971) 401 U.S. 37, 42 [ 27 L.Ed.2d 669 , 91 S.Ct. 746 ]; Middlesex Ethics Comm. v. Garden State Bar Assn. (1982) 457 U.S. 423, 431 [ 73 L.Ed.2d 116 , 102 S.Ct. 2515 ]; Huffman v. Pursue, Ltd. (1975) 420 U.S. 592, 604 [ 43 L.Ed.2d 482 , 95 S.Ct. 1200 ]), which confirmed Congress’s intent to permit state courts to try cases free from federal court interference and under appropriate circumstances, bars the prosecution of a concurrent federal action.

2010The court also rested its decision on abstention under the Younger doctrine (Younger v. Harris (1971) 401 U.S. 37, 42 [ 27 L.Ed.2d 669 , 91 S.Ct. 746 ]; Middlesex Ethics Comm. v. Garden State Bar Assn. (1982) 457 U.S. 423, 431 [ 73 L.Ed.2d 116 , 102 S.Ct. 2515 ]; Huffman v. Pursue, Ltd. (1975) 420 U.S. 592, 604 [ 43 L.Ed.2d 482 , 95 S.Ct. 1200 ]), which confirmed Congress’s intent to permit state courts to try cases free from federal court interference and under appropriate circumstances, bars the prosecution of a concurrent federal action.

22
People v. Becerragreen
calctapp · 2019 · cited in 1 California opinions naming this issue, 2025–2025
1 sentence

2025Appellate Waiver and Certificate of Probable Cause The Attorney General argues that we may not consider Younger’s challenge to the court’s restitution order because she waived her right to appeal and should have obtained a certificate of probable cause. (§ 1237.5; Cal. Rules of Court, rule 8.304(b); see People v. Becerra (2019) 32 Cal.App.5th 178, 185 (Becerra); People v. Panizzon (1996) 13 Cal.4th 68, 86 .) The Attorney General contends that Younger is challenging the trial court’s authority to order restitution at all, not just the amount.

11
People v. Lentgreen
cal · 1975 · cited in 1 California opinions naming this issue, 2025–2025
1 sentence

2025Even if Younger’s claim is cognizable on appeal, the Attorney General adds, the trial court had broad discretion to impose restitution as a condition of probation pursuant to section 1203.1, including as to offenses or conduct for which Younger was not charged or convicted, and in this case the restitution amount is reasonably related to Younger’s criminal conduct, consistent with the factors set forth in People v. Lent (1975) 15 Cal.3d 481, 486 (Lent).

11
Younger v. Harrisgreen
scotus · 1971 · cited in 1 California opinions naming this issue, 2010–2010
2 sentences

2010The court also rested its decision on abstention under the Younger doctrine (Younger v. Harris (1971) 401 U.S. 37, 42 [ 27 L.Ed.2d 669 , 91 S.Ct. 746 ]; Middlesex Ethics Comm. v. Garden State Bar Assn. (1982) 457 U.S. 423, 431 [ 73 L.Ed.2d 116 , 102 S.Ct. 2515 ]; Huffman v. Pursue, Ltd. (1975) 420 U.S. 592, 604 [ 43 L.Ed.2d 482 , 95 S.Ct. 1200 ]), which confirmed Congress’s intent to permit state courts to try cases free from federal court interference and under appropriate circumstances, bars the prosecution of a concurrent federal action.

2010The court also rested its decision on abstention under the Younger doctrine (Younger v. Harris (1971) 401 U.S. 37, 42 [ 27 L.Ed.2d 669 , 91 S.Ct. 746 ]; Middlesex Ethics Comm. v. Garden State Bar Assn. (1982) 457 U.S. 423, 431 [ 73 L.Ed.2d 116 , 102 S.Ct. 2515 ]; Huffman v. Pursue, Ltd. (1975) 420 U.S. 592, 604 [ 43 L.Ed.2d 482 , 95 S.Ct. 1200 ]), which confirmed Congress’s intent to permit state courts to try cases free from federal court interference and under appropriate circumstances, bars the prosecution of a concurrent federal action.

11
Huffman v. Pursue, Ltd.green
scotus · 1975 · cited in 1 California opinions naming this issue, 2010–2010
2 sentences

2010The court also rested its decision on abstention under the Younger doctrine (Younger v. Harris (1971) 401 U.S. 37, 42 [ 27 L.Ed.2d 669 , 91 S.Ct. 746 ]; Middlesex Ethics Comm. v. Garden State Bar Assn. (1982) 457 U.S. 423, 431 [ 73 L.Ed.2d 116 , 102 S.Ct. 2515 ]; Huffman v. Pursue, Ltd. (1975) 420 U.S. 592, 604 [ 43 L.Ed.2d 482 , 95 S.Ct. 1200 ]), which confirmed Congress’s intent to permit state courts to try cases free from federal court interference and under appropriate circumstances, bars the prosecution of a concurrent federal action.

2010The court also rested its decision on abstention under the Younger doctrine (Younger v. Harris (1971) 401 U.S. 37, 42 [ 27 L.Ed.2d 669 , 91 S.Ct. 746 ]; Middlesex Ethics Comm. v. Garden State Bar Assn. (1982) 457 U.S. 423, 431 [ 73 L.Ed.2d 116 , 102 S.Ct. 2515 ]; Huffman v. Pursue, Ltd. (1975) 420 U.S. 592, 604 [ 43 L.Ed.2d 482 , 95 S.Ct. 1200 ]), which confirmed Congress’s intent to permit state courts to try cases free from federal court interference and under appropriate circumstances, bars the prosecution of a concurrent federal action.

11
Mission Oaks Mobile Home Park, a California General Partnership v. City of Hollister Hollister Mobilehome Rent Commissiongreen
ca9 · 1993 · cited in 1 California opinions naming this issue, 2006–2006
2 sentences

2006The Younger doctrine espouses “a strong federal policy against federal-court interference with pending state judicial proceedings absent extraordinary circumstances.” (Middlesex Ethics Comm. v. Garden State Bar Assn. (1982) 457 U.S. 423, 431 [ 73 L.Ed.2d 116 , 102 S.Ct. 2515 ].) “Younger abstention is required if the state proceedings are (1) ongoing, (2) implicate important state interests, and (3) provide the plaintiff an adequate opportunity to litigate federal claims. [Citation.]” (The San Remo Hotel v. City and County of San Francisco (9th Cir. 1998) 145 F.3d 1095 , 1103.) The district co

2006The Younger doctrine espouses “a strong federal policy against federal-court interference with pending state judicial proceedings absent extraordinary circumstances.” (Middlesex Ethics Comm. v. Garden State Bar Assn. (1982) 457 U.S. 423, 431 [ 73 L.Ed.2d 116 , 102 S.Ct. 2515 ].) “Younger abstention is required if the state proceedings are (1) ongoing, (2) implicate important state interests, and (3) provide the plaintiff an adequate opportunity to litigate federal claims. [Citation.]” (The San Remo Hotel v. City and County of San Francisco (9th Cir. 1998) 145 F.3d 1095 , 1103.) The district co

11
Helfend v. Southern California Rapid Transit Districtgreen
cal · 1970 · cited in 1 California opinions naming this issue, 1991–1991
2 sentences

1991See also Helfend v. Southern Cal. Rapid Transit Dist. (1970) 2 Cal.3d 1 [ 84 Cal.Rptr. 173 , 465 P.2d 61 , 77 A.L.R.3d 398 ]; State Dept, of Corrections v. Workmen’s Comp.

1991See also Helfend v. Southern Cal. Rapid Transit Dist. (1970) 2 Cal.3d 1 [ 84 Cal.Rptr. 173 , 465 P.2d 61 , 77 A.L.R.3d 398 ]; State Dept, of Corrections v. Workmen’s Comp.

11
Wooley v. Maynardgreen
scotus · 1977 · cited in 1 California opinions naming this issue, 1980–1980
2 sentences

1980(See generally, Laycock, Federal Interference with State Prosecutions: The Need for Prospective Relief, 1977 Sup.Ct.Rev. 193.) In any event the high court has recently stated that the Younger doctrine does not state “an absolute policy and in some circumstances injunctive relief may be appropriate. ‘To justify such interference there must be exceptional circumstances and a clear showing that an injunction is necessary in order to afford adequate protection of constitutional rights.’ Spielman Motor Co. [(1935) 295 U.S.] at 95. . . .” (Wooley v. Maynard (1977) 430 U.S. 705, 712 [ 51 L.Ed.2d 752,

1980(See generally, Laycock, Federal Interference with State Prosecutions: The Need for Prospective Relief, 1977 Sup.Ct.Rev. 193.) In any event the high court has recently stated that the Younger doctrine does not state “an absolute policy and in some circumstances injunctive relief may be appropriate. ‘To justify such interference there must be exceptional circumstances and a clear showing that an injunction is necessary in order to afford adequate protection of constitutional rights.’ Spielman Motor Co. [(1935) 295 U.S.] at 95. . . .” (Wooley v. Maynard (1977) 430 U.S. 705, 712 [ 51 L.Ed.2d 752,

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in California. Read the followed side critically anyway.

Also cited on this issue (9)

CaseCitedYears
San Remo Hotel v. City of San Francisco green
ca9 · 1998
2 sentences

2010(The San Remo Hotel v. City and County of San Francisco (9th Cir. 1998) 145 F.3d 1095, 1103 .) If the Younger doctrine applies, the concurrent federal action must be dismissed, as the action was here.

2010(The San Remo Hotel v. City and County of San Francisco (9th Cir. 1998) 145 F.3d 1095, 1103 .) If the Younger doctrine applies, the concurrent federal action must be dismissed, as the action was here.

22006–2010
People v. Panizzon green
cal · 1996
1 sentence

2025Appellate Waiver and Certificate of Probable Cause The Attorney General argues that we may not consider Younger’s challenge to the court’s restitution order because she waived her right to appeal and should have obtained a certificate of probable cause. (§ 1237.5; Cal. Rules of Court, rule 8.304(b); see People v. Becerra (2019) 32 Cal.App.5th 178, 185 (Becerra); People v. Panizzon (1996) 13 Cal.4th 68, 86 .) The Attorney General contends that Younger is challenging the trial court’s authority to order restitution at all, not just the amount.

12025–2025
Kizer v. County of San Mateo green
cal · 1991
2 sentences

2021(Id. at pp. 37-39.) As the Kizer court explained, “[i]n essence, the Younger analysis presumed that Government Code section 818 was applicable and concluded that even if the Tort Claims Act applied, the port was liable for the civil penalties.” (Kizer, supra, 53 Cal.3d at p. 144 .) 23 that it would be actionable if inflicted by a private person.’ ” (Ibid., quoting Gov.

2021(Id. at pp. 37-39.) As the Kizer court explained, “[i]n essence, the Younger analysis presumed that Government Code section 818 was applicable and concluded that even if the Tort Claims Act applied, the port was liable for the civil penalties.” (Kizer, supra, 53 Cal.3d at p. 144 .) 23 that it would be actionable if inflicted by a private person.’ ” (Ibid., quoting Gov.

12021–2021
Los Angeles County Metropolitan Transportation Authority v. Superior Court green
calctapp · 2004
2 sentences

2021Code, § 810.8.) Thus, the Kizer court explained, “Government Code section 818 in context means that, under the Tort Claims Act, a plaintiff who alleges injury caused by a public entity may be entitled to actual damages for that injury, but not punitive damages.” (Kizer, at p. 145, italics added.) Consistent with that interpretation, our Supreme Court observed there was “nothing in the Tort Claims Act to suggest that Government Code section 818 was intended to apply to statutory civil penalties designed to ensure compliance with a detailed regulatory scheme, . . . even though they may have a pu

2021Code, § 810.8.) Thus, the Kizer court explained, “Government Code section 818 in context means that, under the Tort Claims Act, a plaintiff who alleges injury caused by a public entity may be entitled to actual damages for that injury, but not punitive damages.” (Kizer, at p. 145, italics added.) Consistent with that interpretation, our Supreme Court observed there was “nothing in the Tort Claims Act to suggest that Government Code section 818 was intended to apply to statutory civil penalties designed to ensure compliance with a detailed regulatory scheme, . . . even though they may have a pu

12021–2021
People v. Vasquez green
cal · 2006
2 sentences

2012As we have previously noted, [Penal Code] section 1424 was enacted in part to tighten the standards for recusal so that a mere appearance of impropriety would not itself suffice; the statutory standard focuses instead on the actual likelihood of unfair treatment.” (People v. Vasquez, supra, 39 Cal.4th at p. 69 .) Thereafter, the Supreme Court has continued applying the Penal Code section 1424 standard, and not the Younger standard, in criminal matters where the disqualification of the prosecutor has been sought.

2012As we have previously noted, [Penal Code] section 1424 was enacted in part to tighten the standards for recusal so that a mere appearance of impropriety would not itself suffice; the statutory standard focuses instead on the actual likelihood of unfair treatment.” (People v. Vasquez, supra, 39 Cal.4th at p. 69 .) Thereafter, the Supreme Court has continued applying the Penal Code section 1424 standard, and not the Younger standard, in criminal matters where the disqualification of the prosecutor has been sought.

12012–2012
City & County of San Francisco v. Cobra Solutions, Inc. green
cal · 2006
2 sentences

2012Although the statute, which triggers disqualification of a prosecutor from a criminal proceeding ‘only if’ the conflict is ‘ “so grave as to render it unlikely that [the] defendant will receive fair treatment” ’ [citation], has superseded Younger's holding [citation], the concerns that the Court of Appeal in Younger expressed about conflicted heads of public law offices, whose policymaking and supervisory duties are such as to preclude them from being effectively screened, have not lost their relevance.” (Cobra Solutions, supra, 38 Cal.4th at p. 850 .) Spaccia would interpret the Supreme Court

2012Although the statute, which triggers disqualification of a prosecutor from a criminal proceeding ‘only if’ the conflict is ‘ “so grave as to render it unlikely that [the] defendant will receive fair treatment” ’ [citation], has superseded Younger's holding [citation], the concerns that the Court of Appeal in Younger expressed about conflicted heads of public law offices, whose policymaking and supervisory duties are such as to preclude them from being effectively screened, have not lost their relevance.” (Cobra Solutions, supra, 38 Cal.4th at p. 850 .) Spaccia would interpret the Supreme Court

12012–2012
Delta Dental Plan of California, Inc. v. Mendoza green
ca9 · 1998
2 sentences

2010(Delta Dental Plan of California, Inc. v. Mendoza (9th Cir. 1998) 139 F.3d 1289, 1294 .) Attorney Wallace’s application for appointment as counsel pro hac vice was initially denied because there was no California attorney associated as attorney of record.

2010(Delta Dental Plan of California, Inc. v. Mendoza (9th Cir. 1998) 139 F.3d 1289, 1294 .) Attorney Wallace’s application for appointment as counsel pro hac vice was initially denied because there was no California attorney associated as attorney of record.

12010–2010
Green v. City of Tucson green
ca9 · 2001
2 sentences

2006The Younger doctrine espouses “a strong federal policy against federal-court interference with pending state judicial proceedings absent extraordinary circumstances.” (Middlesex Ethics Comm. v. Garden State Bar Assn. (1982) 457 U.S. 423, 431 [ 73 L.Ed.2d 116 , 102 S.Ct. 2515 ].) “Younger abstention is required if the state proceedings are (1) ongoing, (2) implicate important state interests, and (3) provide the plaintiff an adequate opportunity to litigate federal claims. [Citation.]” (The San Remo Hotel v. City and County of San Francisco (9th Cir. 1998) 145 F.3d 1095 , 1103.) The district co

2006The Younger doctrine espouses “a strong federal policy against federal-court interference with pending state judicial proceedings absent extraordinary circumstances.” (Middlesex Ethics Comm. v. Garden State Bar Assn. (1982) 457 U.S. 423, 431 [ 73 L.Ed.2d 116 , 102 S.Ct. 2515 ].) “Younger abstention is required if the state proceedings are (1) ongoing, (2) implicate important state interests, and (3) provide the plaintiff an adequate opportunity to litigate federal claims. [Citation.]” (The San Remo Hotel v. City and County of San Francisco (9th Cir. 1998) 145 F.3d 1095 , 1103.) The district co

12006–2006
Gilbertson v. Albright green
ca9 · 2004
2 sentences

2006The Younger doctrine espouses “a strong federal policy against federal-court interference with pending state judicial proceedings absent extraordinary circumstances.” (Middlesex Ethics Comm. v. Garden State Bar Assn. (1982) 457 U.S. 423, 431 [ 73 L.Ed.2d 116 , 102 S.Ct. 2515 ].) “Younger abstention is required if the state proceedings are (1) ongoing, (2) implicate important state interests, and (3) provide the plaintiff an adequate opportunity to litigate federal claims. [Citation.]” (The San Remo Hotel v. City and County of San Francisco (9th Cir. 1998) 145 F.3d 1095 , 1103.) The district co

2006The Younger doctrine espouses “a strong federal policy against federal-court interference with pending state judicial proceedings absent extraordinary circumstances.” (Middlesex Ethics Comm. v. Garden State Bar Assn. (1982) 457 U.S. 423, 431 [ 73 L.Ed.2d 116 , 102 S.Ct. 2515 ].) “Younger abstention is required if the state proceedings are (1) ongoing, (2) implicate important state interests, and (3) provide the plaintiff an adequate opportunity to litigate federal claims. [Citation.]” (The San Remo Hotel v. City and County of San Francisco (9th Cir. 1998) 145 F.3d 1095 , 1103.) The district co

12006–2006

Statutes the citing opinions construe

CA § Cal. Evidence Code § 452 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 7 (1980–2025) MO 3 (1995–2022) KS 2 (2024–2025) FL 2 (1981–1982)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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