Mitchum v. Foster
United States Supreme Court
407 U.S. 225 (1972)
A Florida prosecutor sued in state court to close Mitchum's (plaintiff) bookstore as a public nuisance, and a state court entered a preliminary injunction shutting it down; when further state proceedings stalled, Mitchum sued state officials (defendants) in federal court under 42 U.S.C. § 1983, alleging First and Fourteenth Amendment violations and seeking an injunction staying the state proceedings. The district court denied relief, holding the federal anti-injunction statute (28 U.S.C. § 2283) barred a stay of the state case under existing precedent, and the U.S. Supreme Court granted certiorari.
Whether 42 U.S.C. § 1983 claims are an expressly authorized exception to the federal anti-injunction statute, 28 U.S.C. § 2283.