In
O'Shea, plaintiffs filed a federal lawsuit asserting that a municipal court system was intentionally discriminating against African Americans in setting bail and in sentencing.
414 U.S. at 491–92, 94 S.Ct. 669. The district court dismissed the case, but this court reversed, holding that if plaintiffs proved their allegations, the district court should fashion appropriate injunctive relief to prevent the state court judges from depriving others of their constitutional rights in the future.
Id. at 492–93, 94 S.Ct. 669. The Supreme Court granted certiorari and reversed this court, finding that the claims were not ripe because there was an insufficient probability that the plaintiffs would be brought before the municipal courts again on criminal charges.
Id. at 495–99, 94 S.Ct. 669. The Court also found that even if the claims were ripe, the principles of
Younger should lead the federal courts to abstain. The Court reasoned that comity and federalism “preclude[d] equitable intervention” because the plaintiffs sought “an injunction aimed at controlling or preventing the occurrence of specific events that might take place in the course of future state criminal trials.”
Id. at 499–500, 94 S.Ct. 669. The Court cautioned against injunctions that would lead to “an ongoing federal audit of state criminal proceedings which would indirectly accomplish the kind of interference that
Younger v. Harris ... and related cases sought to prevent.”
Id. at 500, 94 S.Ct. 669.