Abstract
Most essentially, federal and state courts are complementary systems for administering justice in our Nation. Cooperation and comity, not competition and conflict, are essential to the federal design. A State's dignitary interest bears consideration when a district court exercises discretion in a case of this order." This passage penned by Justice Ginsberg recognizes the need for cooperation and comity between state and federal courts. These ideals are deeply imperiled when a federal court exercises its equitable discretion to enjoin ongoing state proceedings. The Supreme Court sought to protect the state judiciary from unnecessary federal court intervention in Younger v. Harris. However, the recent Ninth Circuit decision in United States v. Morros threatens to significantly limit the application of Younger on the basis of party status.
Recommended Citation
Kevin Beck,
The Ninth Circuit's Message to Nevada: You're Not Getting any Younger,
3
Nev. L.J.
592
(2003).
Available at:
https://scholars.law.unlv.edu/nlj/vol3/iss3/7