Ohio Civil Rights Commission v. Dayton Christian Public Schools, Inc. (1985)
- Docket
- 85-488
- Decided
- 1985-01-01
Summary
Question: Should the district court have abstained from adjudicating the case? Conclusion: Yes. Justice William H. Rehnquist delivered the opinion of the 9-0 majority. The Supreme Court held that federal courts should abstain from adjudicating civil state proceedings in which important state interests are involved. As long as the plaintiff has a full and fair opportunity to litigate the constitutional claim, there is no reason for the district court to become involved. Because the Ohio court has the authority to consider whether the Commission’s actions violated the First Amendment, the issue can be fully addressed in state court. Justice John Paul Stevens wrote a concurring opinion where he argued that the district court’s decision on the merits of the case was correct. The Commission merely investigated a complaint based on Dayton’s conduct and filed suit; there was no evidence that the Commission intended to impose a sanction. Without the threat of a sanction, there is no potential constitutional violation. Justice William J. Brennan, Jr., Justice Thurgood Marshall, and Justice Harry A. Blackmun joined in the concurrence.