Case Citator › Middlesex County Ethics Committee v. Garden State Bar Ass'n

Middlesex County Ethics Committee v. Garden State Bar Ass'n

Is it still good law? What later courts have actually done to this case.

Limited by some courts
Court
Supreme Court of the United States
Citation
457 U.S. 423
Decided
Confirmed treatments
1
Flagged citations read
52 of 52
Citing cases (total)
52
Treatment dates
2013
Limited by some courts
At least one reviewed court has limited this case’s holding to narrower facts or a narrower rule. No reviewed court has overruled it. Middlesex County Ethics Committee v. Garden State Bar Ass'n remains authority for abstention in state attorney disciplinary proceedings, but its three conditions do not alone require abstention in ordinary parallel civil proceedings. The Supreme Court confined that broader use of Middlesex in Sprint Communications, Inc. v. Jacobs.
More on how this was screened

All 52 flagged citations have been read; the confirmed treatment is listed below.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

52 later cases cite Middlesex County Ethics Committee v. Garden State Bar Ass'n; 52 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Middlesex County Ethics Committee v. Garden State Bar Ass'n?

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Treatments

Limited

  • The Supreme Court held that Middlesex's three conditions were additional considerations within the exceptional categories of Younger abstention, not a sufficient test for ordinary parallel civil proceedings.

    Sprint Communications, Inc. v. Jacobs · Supreme Court of the United States · filed

    We invoked Younger in Middlesex to bar a federal court from entertaining a lawyer's challenge to a New Jersey state ethics committee's pending investigation of the lawyer. Unlike the IUB proceeding here, the state ethics committee's hearing in Middlesex was indeed "akin to a criminal proceeding." As we noted, an investigation and formal complaint preceded the hearing, an agency of the State's Supreme Court initiated the hearing, and the purpose of the hearing was to determine whether the lawyer should be disciplined for his failure to meet the State's standards of professional conduct. 457 U.S., at 433-435, 102 S.Ct. 2515. See also id., at 438, 102 S.Ct. 2515 (Brennan, J., concurring in judgment) (noting the "quasi-criminal nature of bar disciplinary proceedings"). The three Middlesex conditions recited above were not dispositive; they were, instead, additional factors appropriately considered by the federal court before invoking Younger.
    Read the full opinion on CourtListener →

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