Second Circuit Holds That Younger Abstention Does Not Apply to State Probate Court Order Concerning the Validity of a Lien

In Cavanaugh v. Geballe, No.21-571 (2d Cir. Mar. 17, 2022), the Second Circuit holds that the district court erred by abstaining under the doctrine established in Younger v. Harris, 401 U.S. 37 (1971), from hearing a due process challenge to a statutory lien on plaintiff’s inheritance and grandmother’s estate. The panel holds that a state probate proceeding is not a pending state action “uniquely in furtherance of the state courts’ ability to perform their judicial functions” under Sprint Commc’ns, Inc. v. Jacobs, 571 U.S. 69, 78 (2013).

“In July 2018 a probate proceeding was commenced in the Connecticut State Probate Court for the District of Saybrook to administer the will of Cavanaugh’s deceased grandmother, DiBirma Burnham. The probate court determined that Cavanaugh was to inherit $44,565.96 under the will. In March 2019, however, the Commissioner of the Department of Administrative Services of the State of Connecticut (the ‘Commissioner’ or ‘DAS’) filed a state statutory claim against the Burnham estate under Connecticut General Statutes §§ 17b-93, 17b-94, 17b-224, 18-85b, 46b-129, and46b-130, seeking the lesser of $57,915 or fifty percent of Cavanaugh’s distributive share of the estate for repayment of the medical services Cavanaugh received in 2011.”

The state probate court, over Cavanaugh’s objection, held that his share of the estate was subject to the lien. Cavanaugh then filed in federal district court challenging the lien on federal constitutional and statutory grounds. The district court dismissed on subject-matter jurisdiction grounds, holding that invalidating the state-court lien fell into the category of “exceptional circumstances” relating to civil proceedings that required Younger abstention.

The Second Circuit reverses. “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.’”

In this case, the defendant and the district court relied only on the third of these exceptions. The panel concurs, regarding the other exceptions, that the “probate proceeding at issue is not at all similar to a state criminal prosecution or civil enforcement proceeding.”

The panel holds that third exception does not apply, either. “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 . . . . [W]e 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’ ability to perform their judicial functions.’”

“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,’ . . . . nor implicates a process 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 orders, and neither party challenges the probate court’s basic authority to enforce its orders or adjudicate the matters before it.”

“Because Cavanaugh’s federal action does not fall within Sprint’s third category, we conclude that abstention under Younger was not warranted. 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.”

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