Deakins v. Monaghan
In Deakins v. Monaghan, U.S. 108 S.Ct. 523, 98 L.Ed.2d 529 (1988), the plaintiffs brought a section 1983 action seeking equitable relief, compensatory and punitive damages, and attorney's fees for alleged violations of their constitutional rights.
Their federal claims arose out of an ongoing grand jury investigation. The district court dismissed the action on abstention grounds and denied the plaintiff's motion for injunctive relief.
The Court of Appeals for the Third Circuit reversed the dismissal of the complaint.
After ruling that the abstention doctrine did not require the district court to abstain from adjudicating the plaintiff's claim for injunctive relief arising out of an ongoing grand jury investigation, the court also held that the district courts, when abstaining from adjudicating a claim for injunctive relief, should stay rather than dismiss accompanying claims for monetary relief and attorney's fees when such relief is not available from the ongoing state proceeding.
The court noted that the availability of a separate state tribunal in which the monetary claims could be brought did nothing to lessen the district court's obligation to retain jurisdiction over claims properly before it. See Monaghan v. Deakins, 798 F.2d 632, 635-36 (3d Cir.1986).
The Court granted certiorari to consider whether the district court was required to abstain from adjudicating the plaintiff's claim for injunctive relief, and whether the court had the discretion to dismiss, rather than stay, plaintiff's additional claims for damages and attorney's fees. While the case was pending, the plaintiffs expressed a willingness to withdraw their equitable claims, thereby rendering moot the question of whether the district court was required to abstain from adjudicating the claims for equitable relief.
The Court reached the second issue, however, and found the Third Circuit's rule to be sound and held that the district court has no discretion to dismiss rather than stay claims that are not cognizable in the parallel state proceeding. Deakins, 108 S.Ct. at 530.