Disability Rights New York v. New York, No. 17-2812 (2d Cir. 2019)Annotate this Case
The Second Circuit affirmed the district court's order granting defendants' motion for judgment on the pleadings and dismissing the complaint, which alleged constitutional and other deficiencies in the manner in which guardianship proceedings are conducted in New York Surrogate's Court under Article 17A of the Surrogate's Court Procedure Act. The district court did not reach the merits of the complaint, abstaining pursuant to Younger v. Harris, 401 U.S. 37 (1971), and OʹShea v. Littleton, 414 U.S. 488 (1974).
In this case, the requested relief would effect a continuing, impermissible "audit" of New York Surrogate's Court proceedings, which would offend the principles of comity and federalism. The court held that it had no power to intervene in the internal procedures of the state courts, and could not legislate and engraft new procedures upon existing state practices. Therefore, the district court correctly abstained from exercising jurisdiction in this case. The court noted that abstention was supported by the availability of other revenues of relief where any aggrieved individuals would be able to obtain sufficient review in state court and, if needed, the Supreme Court of the United States.