Establishing the Threshold for “Extraordinary Circumstances” Under Younger Abstention in Federal Challenges to Ongoing State Criminal Proceedings

Introduction

This commentary examines the Third Circuit’s unpublished decision in Jason Samaritano v. State of New Jersey, No. 24-1889 (3d Cir. June 2, 2025), which addresses the application of the Younger abstention doctrine to a federal civil-rights lawsuit challenging pending state-court criminal proceedings. The appellant, Jason Samaritano, had pleaded guilty in New Jersey state court to fraud and stalking charges. Before sentencing, he filed a § 1983 action in federal district court alleging (1) a statewide conspiracy against him, (2) unconstitutional overbreadth in New Jersey’s cyber-harassment statute, and (3) denial of his Sixth Amendment right to counsel. He sought injunctive relief to stay his state-court sentencing. The district court declined to enjoin the state proceedings under Younger v. Harris (401 U.S. 37 (1971)), and Samaritano appealed.

Summary of the Judgment

On de novo review, the Third Circuit affirmed the district court’s denial of preliminary injunctive relief. It held that Younger abstention bars federal courts from enjoining ongoing state criminal prosecutions unless “extraordinary circumstances” exist—such as bad faith, harassment, or a patently invalid statute—that give rise to an immediate and irreparable injury. The court found that:

Samaritano’s bare assertions of a conspiracy lacked evidentiary support and did not demonstrate bad faith or harassment;
The New Jersey cyber-harassment statute under which he was prosecuted was not patently invalid;
He had adequate remedies in the state court system (e.g., direct appeals, collateral challenges); and
No extraordinary circumstances justified federal intervention.

Accordingly, Younger compelled abstention, and the Third Circuit affirmed the denial of the stay.

Analysis

Precedents Cited

The court’s ruling rests on a well-developed Younger abstention framework and related authorities:

Younger v. Harris (401 U.S. 37 (1971)): Established that federal courts should not enjoin ongoing state criminal prosecutions except in extraordinary circumstances.
Kugler v. Helfant (421 U.S. 117 (1975)): Clarified that “bad faith” prosecution requires demonstration that charges were brought without a reasonable expectation of conviction.
Sprint Commc’ns v. Jacobs (571 U.S. 69 (2013)): Reaffirmed Younger abstention’s “virtually unflagging obligation” exception and enumerated the categories—bad faith, harassment, patently invalid statutes—that might warrant relief.
Evans v. Court of Common Pleas (959 F.2d 1227 (3d Cir. 1992)): Held that even claims of prosecutorial vindictiveness do not ordinarily overcome Younger unless the defendant can show double jeopardy or similarly exceptional harm.
State case law upholding New Jersey’s cyber-harassment statute, including State v. Carroll (196 A.3d 106 (N.J. Super. Ct. App. Div. 2018)), which treated the statute as valid despite probable-cause issues.

Legal Reasoning

The Third Circuit applied the following logical steps:

Existence of Pending State Proceedings. Samaritano’s sentencing had not concluded; the restitution hearing was pending, so the state-court criminal process remained ongoing.
Presumption of Federal Non-Interference. Younger instructs that federal courts generally abstain from enjoining pending state criminal matters.
Extraordinary-Circumstances Exception. The court examined whether Samaritano had shown bad faith, harassment, or that the cyber-harassment statute was patently invalid.
Evidence Analysis. His allegations of a “state-wide conspiracy” were conclusory and unsupported. There was no credible showing that prosecutors acted without hope of conviction (bad faith) or to harass him.
Statute Validity. The Third Circuit relied on its precedent upholding similar harassment statutes (e.g., United States v. Yung, 37 F.4th 70 (3d Cir. 2022)) and New Jersey decisions treating N.J. Stat. Ann. § 2C:33-4.1(a) as valid.
Adequacy of State Remedies. Samaritano had access to state appellate and post-conviction relief; no evidence showed that the state forum would deny him due process.
Conclusion. Absent extraordinary circumstances, Younger requires abstention, so the federal courts could not enjoin or stay the sentencing.

Impact

This decision, although non-precedential, reinforces key principles for practitioners and litigants:

It underscores the high threshold for invoking the extraordinary-circumstances exception under Younger. Mere allegations of impropriety or constitutional infirmity will not suffice.
It emphasizes that state remedies—including direct appeals, collateral attacks, and post-conviction petitions—are ordinarily “adequate” to vindicate federal rights.
It confirms that broad challenges to statutes as overbroad or vague must be paired with evidence of patent invalidity to avoid abstention.
It signals to defense counsel that federal courts remain closed to injunctive interference in ongoing state prosecutions, promoting respect for state-court processes and judicial federalism.

Complex Concepts Simplified

Below are explanations of key legal doctrines and terms:

Younger Abstention: A doctrine requiring federal courts to refrain from enjoining state-court proceedings, except when the defendant can prove “extraordinary circumstances” such as prosecutorial bad faith or a statute’s unconstitutional overbreadth.
Bad Faith Prosecution: A legal standard demanding proof that state actors filed charges without any hope of conviction—essentially to harass or punish the defendant.
Patently Invalid Statute: A law so deficient on its face (e.g., violates the First Amendment) that it cannot be enforced at all. To overcome Younger, a statute must be shown beyond dispute to be devoid of any constitutional application.
Adequate State Remedies: State procedures (appeal, post-conviction relief) by which a defendant can raise constitutional claims. Demonstrating the absence of these avenues can justify federal intervention.
Preliminary Injunction vs. Abstention: A preliminary injunction is an extraordinary form of relief requiring the court to enjoin ongoing conduct. Younger abstention forbids federal courts from issuing such relief against state prosecutions unless the high bar of extraordinary circumstances is met.

Conclusion

The Third Circuit’s decision in Samaritano v. State of New Jersey clarifies that federal courts must abstain from enjoining ongoing state criminal proceedings unless a defendant meets the stringent “extraordinary circumstances” exception under Younger. Conclusory allegations of conspiracy, unsupported claims of constitutional overbreadth, or generalized Sixth Amendment grievances do not satisfy that exception. Litigants challenging state prosecutions must, therefore, be prepared to demonstrate prosecutorial bad faith, harassment, or an undeniably unconstitutional statute—otherwise, they will be directed back to the state forum for relief. This reaffirmation of federal-state comity underscores the judiciary’s commitment to respect and preserve the integrity of parallel state criminal processes.