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.
