Cavanaugh v. Geballe, 28 F.4th 428

In 2011 Brian Cavanaugh received rehabilitative services while enrolled in Connecticut’s HUSKY D Medicaid plan; the funding source (state vs. federal) was disputed.
A 2018 Connecticut probate proceeding administering his grandmother’s estate determined Cavanaugh’s distributive share would be $44,565.96.
Connecticut’s Department of Administrative Services (DAS) filed a statutory claim asserting a lien under state law seeking repayment (up to $57,915 or 50% of his share) for the 2011 medical services.
The probate court concluded DAS had standing and ordered that 50% of Cavanaugh’s distributive share be applied toward repayment.
Cavanaugh sued in federal court under 42 U.S.C. § 1983, alleging Fourteenth Amendment and Title XIX violations and seeking declaratory and injunctive relief invalidating the statutory lien.
The district court abstained under Younger and dismissed; the Second Circuit vacated, holding Younger does not extend to routine probate lien disputes absent orders uniquely tied to the state courts’ core judicial-administrative or enforcement processes, and remanded for further proceedings (including consideration of the probate exception and merits).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Younger abstention bars federal suit challenging validity of a state statutory lien in probate proceedings	Younger does not apply because this is an ordinary civil probate dispute raising federal statutory and constitutional claims, not one of Sprint’s narrow categories	Younger applies because a federal decision invalidating the lien would interfere with the probate court’s administration of the estate	Younger does not apply; abstention was erroneous—Younger is limited to criminal prosecutions, certain civil enforcement, and civil proceedings involving orders uniquely furthering state courts’ judicial functions (e.g., contempt, bond/posting orders, processes enforcing judgments)
Whether the district court erred in deciding Younger abstention before resolving jurisdictional/probate-exception arguments	Federal court should resolve jurisdiction and merits rather than abstain	District court properly may address Younger threshold first and decline to exercise jurisdiction	No error in resolving Younger first; Second Circuit nonetheless vacated on the merits of abstention and remanded for district court to consider the probate-exception and then, if needed, the merits

Younger v. Harris, 401 U.S. 37 (establishing federal-court abstention doctrine for certain ongoing state proceedings)
Sprint Communications, Inc. v. Jacobs, 571 U.S. 69 (defining Younger’s three narrow categories where abstention is appropriate)
Juidice v. Vail, 430 U.S. 327 (contempt process vindicates state court authority and supports Younger abstention)
Pennzoil Co. v. Texaco, Inc., 481 U.S. 1 (federal injunctions that undermine state processes enforcing judgments implicated Younger concerns)
Falco v. Justices of Matrimonial Parts, 805 F.3d 425 (2d Cir.) (applying Younger to state orders requiring parents to pay court-appointed counsel fees in custody proceedings)
Colorado River Water Conservation Dist. v. United States, 424 U.S. 800 (federal courts generally have a strong duty to exercise jurisdiction)