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Zwickler v. Koota, 389 U.S. 241 (1967)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Zwickler v. Koota, 389 U.S. 241 (1967)
Zwickler v. Koota No. 29 Argued October 12, 1967 Decided December 5, 1967 389 U.S. 241
APPEAL FROM THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF NEW YORK
Syllabus
Reversal on state law grounds of appellant’s conviction of violating a New York statute by distributing anonymous political handbills was affirmed by the State’s highest court. Thereafter appellant, invoking federal jurisdiction under the Civil Rights Act and the Declaratory Judgment Act, sought in the District Court declaratory relief and an injunction against future criminal prosecutions for violating the statute, claiming that, on its face, the statute contravened the First Amendment by its "overbreadth." A three-judge court applied the doctrine of abstention and dismissed the complaint, leaving the appellant to assert his constitutional challenge in the state courts either in the defense of any criminal prosecution for future violations of the statute or by way of a declaratory judgment action. The court held that abstention from ruling on the declaratory judgment issue was warranted because appellant had made no special showing of the need for an injunction against criminal prosecution.
Held:
1. The District Court erred in refusing to pass on appellant’s claim for a declaratory judgment as there was no "special circumstance" warranting its application of the abstention doctrine to that claim. Pp. 245-252.
(a) A federal court has the duty of giving due respect to a suitor’s choice of a federal forum for the hearing and decision of his federal constitutional claims and escape from that duty is not permissible merely because state courts are equally responsible for the enforcement and protection of federal constitutional rights. P. 248.
(b) A statutory construction by the state courts would not avoid or modify the constitutional question as the statute involved here is being challenged not for its lack of clarity, but for its "overbreadth." Pp. 249-250.
(c) The principle that abstention cannot be used simply to give the state courts the first opportunity to vindicate a federal claim is particularly significant when, as here, the statute is being attacked as repugnant to the First Amendment, for the delay from requiring recourse to the state courts might chill the very constitutional right which a plaintiff seeks to protect. P. 252.
2. The District Court had the duty of adjudicating the request for a declaratory judgment regardless of its conclusion as to the propriety of the issuance of an injunction, for, as Dombrowski v. Pfister, 380 U.S. 479, made clear, the questions of abstention and of injunctive relief are not the same. Pp. 252-255.
261 F.Supp. 985, reversed and remanded.
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Chicago: U.S. Supreme Court, "Syllabus," Zwickler v. Koota, 389 U.S. 241 (1967) in 389 U.S. 241 389 U.S. 242. Original Sources, accessed November 24, 2024, http://originalsources.com/Document.aspx?DocID=264ETL8K7QUDQSR.
MLA: U.S. Supreme Court. "Syllabus." Zwickler v. Koota, 389 U.S. 241 (1967), in 389 U.S. 241, page 389 U.S. 242. Original Sources. 24 Nov. 2024. http://originalsources.com/Document.aspx?DocID=264ETL8K7QUDQSR.
Harvard: U.S. Supreme Court, 'Syllabus' in Zwickler v. Koota, 389 U.S. 241 (1967). cited in 1967, 389 U.S. 241, pp.389 U.S. 242. Original Sources, retrieved 24 November 2024, from http://originalsources.com/Document.aspx?DocID=264ETL8K7QUDQSR.
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