Hawaii Housing Authority v. Midkiff

Summary

Justice Rehnquist, acting as Circuit Justice, denied without prejudice an application by the Hawaii Housing Authority and related applicants to stay or vacate a Ninth Circuit injunction concerning enforcement of Hawaii’s Land Reform Act. The opinion addresses appellate jurisdiction, recall of an appellate mandate, equitable injunction requirements, and the potential application of Younger abstention principles to state condemnation proceedings.

Holdings

1. A court retains power to grant injunctive relief preserving the status quo during the pendency of an appeal, including an appeal to the Supreme Court.
2. Recall of a mandate is an extraordinary remedy within the inherent power of a court of appeals and is reviewable for abuse of discretion.
3. The principles of Younger abstention apply to federal injunctions against noncriminal state judicial proceedings when important state interests are involved, subject to exceptions where state law clearly bars constitutional claims or extraordinary circumstances require equitable relief.

Questions Presented

1. Whether the Ninth Circuit retained authority to recall and clarify its mandate after a notice of appeal to the Supreme Court had been filed.
2. Whether the Ninth Circuit's recall of its mandate was an abuse of discretion.
3. Whether the Ninth Circuit's injunction against state proceedings implicated or violated the principles of federalism and abstention recognized in Younger v. Harris and related cases.
4. Whether the Circuit Justice should stay or vacate the Ninth Circuit's interlocutory order.

Disposition

writ_denied