Wednesday, June 18, 2014

federal courts - Younger abstention

Gonzalez v. Waterfront Commission – 3d Cir. – June 17, 2014

Ariel Gonzalez filed this action against his former employer, the Waterfront Commission of the New York Harbor, seeking to enjoin disciplinary proceedings initiated by the Commission as a violation of his rights under Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act (“ADA”), and the First Amendment.

The United States District Court for the District of New Jersey denied Gonzalez’s motion and ultimately stayed and administratively terminated this suit based on its conclusion that the Younger1 abstention doctrine precluded federal interference with the ongoing state disciplinary proceedings.

During the pendency of this appeal, the Supreme Court issued its decision in Sprint Communications, Inc. v. Jacobs, 134 S. Ct. 584 (2013), which provides clarity to the abstention inquiry and defines the outer boundaries of the abstention doctrine.

Reviewing this appeal in light of Sprint, we conclude that the decision to abstain was appropriate. Accordingly, we will affirm.