BRIAN CAVANAUGH v. JOSH GEBALLE, IN HIS OFFICIAL CAPACITY AS COMMISSIONER OF THE DEPARTMENT OF ADMINISTRATIVE SERVICES OF THE STATE OF CONNECTICUT
21-571-cv
UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT
March 17, 2022
August Term, 2021
(Argued: December 14, 2021)
Plаintiff Brian Cavanaugh filed this federal action after a Connecticut probate court issued an order recognizing the validity of a state lien against Cavanaugh‘s interest in an estate. The United States District Court for the District of Connecticut (Dooley, J.) applied the doctrine established in Younger v. Harris, 401 U.S. 37 (1971), and abstained from adjudicating Cavanaugh‘s suit because of the ongoing state probate proceеdings. The Younger abstention doctrine is an exception to the general rule that federal courts must hear and decide cases within their jurisdiction. Apart from certain state civil enforcement proceedings, the doctrine applies only to those civil proceedings “involving certain orders uniquely in furtherance of the
JOHN D. WATTS, Clinton, CT, for Plaintiff-Appellant Brian Cavanaugh.
KRISLYN M. LAUNER, Assistant Attorney General (Clare Kindall, Solicitor General, Maria A. Santos, Assistant Attorney General, on the brief), for William Tong, Attorney General of Connecticut, Hartford, CT, for Defendant-Appellee Josh Geballe.
LOHIER, Circuit Judge:
Federal courts have a “virtuаlly unflagging obligation . . . to exercise the jurisdiction given [to] them.” Colorado River Water Conserv. Dist. v. United States, 424 U.S. 800, 817 (1976); see Sprint Commc‘ns, Inc. v. Jacobs, 571 U.S. 69, 77 (2013). Under the Younger abstention1 doctrine, however, federal courts refrain from interfering with three categories of state proceedings. One of these is “pending civil proceedings involving certain orders uniquely in furtherance of the state courts’ ability to perform their judicial functions.” Sprint, 571 U.S. at 78 (cleaned up). In this appeal, whiсh involves a state probate proceeding, we clarify that Younger abstention
BACKGROUND
On October 1, 2011, Brian Cavanaugh, a Connecticut resident, became a member in the HUSKY D health insurance program, a Medicaid health insurance program provided by the Affordable Care Act and offered by Connecticut to its residents. From October 3, 2011, through November 16, 2011, Cavanaugh received “rehabilitation and other services to help to attain or retain capability for independence or self-care.” Compl. ¶ 15. The parties dispute whether federal or state funds were used to pay for these services.2
The executor of Burnham‘s estate later filed a financial accounting report that listed the amounts each beneficiary, including Cavanaugh, was to receive from the estate. The report did not mention the Commissioner‘s lien, however, and it omitted from its list of proposed distributions $30,000 in cash bequests intended for Cavanaugh and his brother. The Commissioner objected to the financial accounting report. The objection, together with the discrepancies between the will and the proposed distributions, prompted the
During the hearing, Watts “argued that DAS had no standing in the matter and should not be allowed to object to the accounting.” Supp. App‘x 14. The probate court ultimately rejected the financial report and ordered “a memo of law that would justify the Proposed Distribution” and “a brief on the issue of DAS‘s standing.” Id. In January 2020, after the executor withdrew the financial report, Watts filed a brief challenging the Commissioner‘s standing on a number of grounds, including that the Commissioner lacked “a legally protected interest in the estate because it is a creditor of a beneficiary and not of the estate.” Id. at 15. The probate court rejected that challenge. Cavanaugh‘s “share of the estate is subject to [the Commissioner‘s] lien” under Connecticut law, the court concluded, and the Commissioner “has the right to object to the Proposed Distribution in the Financial Report” since “[t]he court‘s acceptance or rejection of the Proposed Distribution in the Final Financial Report for the estаte could adversely affect this interest.” Id. at 15–16. The probate court then determined that fifty
Cavanaugh filed this
This appeal followed.
DISCUSSION
We consider whether Younger abstention extends to state probate proceedings that both raise a federal question and concern the validity of a lien against an estate. We conclude that the District Court‘s decision to abstain here was error, and we reverse.4
The Supreme Court has stated that the obligation of federаl courts to hear cases within their jurisdiction is “virtually unflagging.” Colorado River, 424 U.S. at 817. While comity and other interests may sometimes require a district court to abstain from exercising its jurisdiction over a matter out of respect for certain state court functions, see Sprint, 571 U.S. at 77, the Supreme Court has reminded us that abstention is “the exception, not the rule,” id. at 82
In Sprint, the Supreme Court instructed us that a district court should abstain under Younger “only in three exceptional circumstances involving (1) ongoing state criminal prosecutions, (2) certain civil enforcement proceedings, and (3) civil proceedings involving certain orders uniquely in furtherance of the state courts’ ability to perform their judicial functions.” Falco, 805 F.3d at 427 (quoting Sprint, 571 U.S. at 78) (quotation marks omitted). These three exceptions “define Younger‘s scope.” Sprint, 571 U.S. at 78. To be sure, before invoking Younger a federal cоurt may “appropriately consider[]” three additional factors laid out in Middlesex County Ethics Committee v. Garden State Bar Association, 457 U.S. 423 (1982), that further counsel in favor of abstention: Whether “there is (1) an ongoing state judicial proceeding [that] (2) implicates important state interests and (3) provides an adequate opportunity to raise federal сhallenges.” Sprint, 571 U.S. at 81 (cleaned up); see Falco, 805 F.3d at 427. But these conditions “[are] not dispositive; they
In Falco, we applied Sprint‘s “straightforward categorical approach” to conclude that abstention was warranted under the circumstances of that case. 805 F.3d at 427. Falco involved a husband who sued his wife for divorce and also sought custody of their children. A New York state court aрpointed counsel to represent the children during the custody proceedings, as permitted under New York law. Id. at 426. The state court ordered the parents to each pay half of the attorney‘s retainer and fees, but when the husband failed to do so, the court issued an order to show cause as to why he should not be held in contempt. Id. The husband then filed suit in federal court, challenging the constitutionality of the statute authorizing New York state judges to order parents to pay for attorneys appointed for their children. Id. at 427. We held that the husband‘s challenge fell squarely in Sprint‘s third category of proceedings that require federal court abstention. “[O]rders relating to the selection and compensation of court-appointed counsel for children,” we said, “are integral to the State court‘s ability to perform its judicial function in divorce and custody proceedings.” Id. at 428.
To start, the District Court mistakenly reasoned that any action that invalidates the probate court‘s order recognizing the validity of the Commissioner‘s statutory lien would interfere with the probate court‘s ability to oversee the administration of the estate, which the District Court viewed as integral to the probate court‘s performance of its judicial function. Sеe Cavanaugh, 2021 WL 781796, at *3. The broad conclusion that Younger abstention requires a federal court to abstain whenever an action might interfere with a probate court‘s oversight function does not follow from either Sprint or Falco. In particular, we do not believe that the probate court‘s order recognizing the validity of the Commissioner‘s lien in this case qualifies as an order “uniquely in furtherance of the state courts’ аbility to perform their judicial functions.” Falco, 805 F.3d at 427 (quoting Sprint, 571 U.S. at 78).
In Sprint, the Supreme Court identified two types of orders that clearly fall within that category: civil contempt orders and orders requiring the
Likewise, in Falco, our Court determined that the state court order in a divorce and child custody proceeding fit neatly into the third Younger category of exceptional circumstances and warranted abstention. There the federal plaintiff sought to enjoin New York State courts from enforcing their orders requiring parents to pay fees for court-appointed attorneys in child custody cases. See Falco, 805 F.3d at 428. The fees ensured that the children were represented by counsel and, in our view, were necessary for the effective administration and disposition of child custody proceedings and to “vindicat[e] the regular operation” of those proceedings. Juidice, 430 U.S. at 335; see Falco, 805 F.3d at 428.
Juidice and Pennzoil both “involve[d] challenges to the processes by which the State compels compliance with the judgments of its courts.” Pennzoil, 481 U.S. at 13–14 (emphasis added). Similarly, Falco involved a challenge to ”the way that New York courts manage their own divorce and
Here, the probate court‘s order recognizing the Commissioner‘s lien and standing to participate in the proceedings neither “lies at the core of the administration of a State‘s judicial system,” Juidice, 430 U.S. at 335, nor implicates a рrocess that aids the state court‘s core ability to function or force the parties to comply with its order. To the contrary, the probate court‘s order merely affects how the executor administers the estate. In this case, moreover, there is no record of non-compliance with the probate court‘s
In holding otherwise, the District Court was primarily concerned that Cavanaugh‘s challenge, as an attempt to relitigate the validity of the Commissioner‘s lien, would “nullif[y]” the probate court‘s determination. See Cavanaugh, 2021 WL 781796, at *3. Viewed correctly, howеver, the state suit in this case was no more than a run-of-the-mill challenge to a claim for money, while the related federal suit would not hinder the probate court‘s basic authority to enforce its orders. As such, the state suit comes within none of the exceptions that Younger or Sprint established.
The District Court also considered Connecticut‘s interest in having its probate courts properly administer estates within their custody and the possibility that the probate court‘s determination was reviewable on “appeal to the superior court.” See Cavanaugh, 2021 WL 781796, at *3. The District Court appears to have taken its cue in part from a 2005 decision of the Fourth
Because Cavanaugh‘s federal action does not fall within Sprint‘s third category, we conclude that abstention under Younger was not warranted.6 We therefore vacate the District Court‘s judgment and remand for the District Court to consider in the first instance the parties’ arguments regarding the probate exception to federal jurisdiction and, if necessary, the merits of Cavanaugh‘s claims. See Eric M. Berman, P.C. v. City of New York, 796 F.3d 171, 175 (2d Cir. 2015).
CONCLUSION
We have considered the Commissioner‘s remaining arguments regarding whether the District Court properly abstained under Younger and conclude that they are without merit. For the foregoing reasons, we VACATE the judgment of the District Court and REMAND for further proceedings consistent with this opinion.