Supreme Court of the United States

Boyle, Judge v. Landry

February 23, 1971401 U.S. 77

Summary

The Supreme Court reversed the three‑judge district court’s injunction against the Illinois intimidation statute, holding that the plaintiffs lacked standing and that federal courts may not enjoin state criminal prosecutions absent a clear showing of irreparable injury and statutory authority.

Holding

  • Did the plaintiffs have standing to obtain an injunction against enforcement of the intimidation statute?. The plaintiffs lacked standing because they failed to demonstrate any irreparable injury from the threatened prosecutions.
  • Does 28 U.S.C. § 2283 bar a federal injunction against state criminal proceedings?. Yes; the statute prohibits a federal court from granting an injunction to stay state court proceedings absent express congressional authorization.
  • May federal courts enjoin state criminal prosecutions under the Younger abstention doctrine?. No; the federal courts must not interfere with ongoing state criminal prosecutions absent extraordinary circumstances, and the plaintiffs offered none.

Docket 4

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