Tuesday, April 01, 2014

federal courts - abstention - Younger abstention

Acra Turf Club v. Zanzuccki -  3d Cir. – March 341, 2014

ACRA Turf Club, LLC filed this suit pursuant to 42 U.S.C. §§ 1983 and 1988, against Francesco Zanzuccki , Executive Director of the New Jersey Racing Commission, asserting that certain amendments to New Jersey’s Off-Track and Account Wagering Act violate their rights under the United States Constitution.

The District Court dismissed the case on Younger abstention grounds, and Plaintiffs appealed. During the pendency of this appeal, the Supreme Court issued its decision in Sprint Communications, Inc. v. Jacobs, 134 S. Ct. 584 (2013), which clarifies and reminds courts of the boundaries of the Younger abstention doctrine. Because this action does not fit within the framework for abstention outlined in Sprint, we will reverse.