Younger Abstention Bars Federal Injunctions Against State-Court Termination of Appellate Stays in Foreclosure Proceedings

Introduction

In this Second Circuit summary order, the court affirms a district court’s denial of a preliminary injunction sought by a pro se litigant, Aleksandra Toczek, against multiple Connecticut state judges. The dispute arises out of Connecticut foreclosure proceedings in which the state trial court—affirmed by the state appellate court—terminated the automatic appellate stay that ordinarily halts enforcement of a judgment while an appeal is pending. Toczek brought a federal action under 42 U.S.C. § 1983, alleging procedural due process violations and asking the federal court to reinstate her appellate stays and to enjoin Connecticut courts from terminating stays in her foreclosure case.

The key issue on appeal is whether the federal courts may intervene and enjoin state-court orders that manage appellate stays in ongoing foreclosure litigation. The Second Circuit answers no, holding that Younger abstention applies under Sprint’s “third category,” which counsels federal non-interference in state civil proceedings that implicate a state’s interest in enforcing its courts’ orders and judgments.

Summary of the Opinion

The Second Circuit affirms the district court’s denial of Toczek’s motion for a preliminary injunction. It holds that Younger abstention requires federal courts to refrain from interfering with ongoing state foreclosure proceedings and related orders governing appellate stays. The court determines:

The case fits within Sprint Communications, Inc. v. Jacobs’s third Younger category—civil proceedings involving a state’s interest in enforcing the orders and judgments of its courts.
Connecticut’s rules allow trial courts to terminate appellate stays in some circumstances (Conn. Practice Book § 61-11(d)) and empower the Appellate Court to review such orders via motion for review (Conn. Practice Book § 66-6), providing an adequate opportunity to raise federal constitutional claims.
The unavailability of immediate review by the Connecticut Supreme Court or the U.S. Supreme Court does not negate Younger’s application.
Because abstention is dispositive, the court does not reach the Eleventh Amendment question (acknowledging EX PARTE YOUNG but finding it unnecessary to decide).

Case Background

After a judgment of strict foreclosure entered in Connecticut Superior Court against Toczek’s property, the court issued orders terminating appellate stays that would otherwise have prevented enforcement of the foreclosure judgment during appeal. The Connecticut Appellate Court affirmed those orders. Toczek sued one Connecticut Superior Court judge and nine Appellate Court judges in federal district court, alleging due process violations in the termination of her automatic appellate stays. She sought a preliminary injunction directing federal courts to:

Reinstate the appellate stays;
Enjoin the Connecticut Superior Court from terminating future appellate stays; and
Enjoin the Connecticut Appellate Court from affirming such terminations.

The district court denied relief, reasoning that federal courts lack general authority to review or enjoin state-court judicial actions. On appeal, the Second Circuit affirms on Younger abstention grounds.

Detailed Analysis

Precedents and Authorities Cited

YOUNGER v. HARRIS, 401 U.S. 37 (1971): Establishes the abstention doctrine that federal courts should generally refrain from enjoining ongoing state proceedings out of principles of comity and federalism.
Sprint Communications, Inc. v. Jacobs, 571 U.S. 69 (2013): Clarifies that Younger abstention applies only in three “exceptional circumstances”: (1) state criminal prosecutions, (2) certain civil enforcement proceedings akin to criminal prosecutions, and (3) civil proceedings that implicate a state’s interest in enforcing the orders and judgments of its courts. The court uses Sprint’s “straightforward categorical approach.”
Pennzoil Co. v. Texaco, Inc., 481 U.S. 1 (1987): Emphasizes federal courts should “stay their hand” in matters involving the enforcement of state court orders, out of respect for state courts’ ability to resolve federal questions.
KAUFMAN v. KAYE, 466 F.3d 83 (2d Cir. 2006): Applies Younger to claims challenging state appellate court administration (assignment of cases), underscoring the state’s strong interest in the functioning of its courts.
Falco v. Justices of the Matrimonial Parts, 805 F.3d 425 (2d Cir. 2015): Reaffirms, post-Sprint, that federal courts should abstain from interfering in the way state courts manage divorce/custody proceedings; confirms the “third category” applicability.
JUIDICE v. VAIL, 430 U.S. 327 (1977); Middlesex Cnty. Ethics Comm. v. Garden State Bar Ass’n, 457 U.S. 423 (1982): Address the adequacy of state forums to entertain constitutional claims and support abstention where the state provides an opportunity for such review.
KIRSCHNER v. KLEMONS, 225 F.3d 227 (2d Cir. 2000): A plaintiff must show state procedures prevent effective presentation of federal contentions to avoid Younger; no such showing here.
McKNIGHT v. MIDDLETON, 699 F. Supp. 2d 507 (E.D.N.Y. 2010), aff’d, 434 F. App’x 32 (2d Cir. 2011): Supports abstention even when the state order is not immediately appealable.
El Bey v. Bellis, 2019 WL 2502929 (D. Conn. June 17, 2019), appeal dismissed, 2020 WL 3989534 (2d Cir. Apr. 10, 2020): Collects cases applying Younger in the foreclosure context and recognizes Connecticut’s motion-for-review process as an avenue for federal challenges to stay orders.
Disability Rights N.Y. v. New York, 916 F.3d 129 (2d Cir. 2019): Confirms de novo review of whether abstention requirements are met.
Conn. Practice Book §§ 61-11(a), 61-11(d), 66-6: State procedural rules governing automatic stays pending appeal, trial court authority to terminate stays, and appellate review via motion for review.
EX PARTE YOUNG, 209 U.S. 123 (1908): Recognizes a narrow path around Eleventh Amendment immunity for suits seeking prospective relief for ongoing violations of federal law; noted but not reached here because Younger controls.

Legal Reasoning

The court’s analysis has two principal steps: first, whether the case falls within one of Sprint’s three Younger categories; and second, whether the state forum affords an adequate opportunity to raise the federal issues.

1) Sprint’s “Third Category” Is Squarely Implicated

Toczek asked the federal court to reinstate state appellate stays and to prohibit the Connecticut courts from terminating those stays in the future. Such relief would directly intrude upon state courts’ management of their own judgments and orders in an ongoing foreclosure action. Sprint emphasizes that Younger abstention applies to civil proceedings that “implicate a state’s interest in enforcing the orders and judgments of its courts,” and the Supreme Court has underscored that those orders are “uniquely in furtherance of the state courts’ ability to perform their judicial functions.”

The Second Circuit places Toczek’s suit in that precise category: the Connecticut Superior Court acted under Conn. Practice Book § 61-11(d) to terminate stays; the Appellate Court had authority to review via § 66-6; and Toczek sought federal intervention in those very orders. Consistent with Pennzoil, Kaufman, and Falco, the court holds abstention is required to avoid federal entanglement in state judicial administration and enforcement.

2) Adequate Opportunity to Raise Federal Claims in State Court

Toczek argued that because she could not obtain immediate review by the Connecticut Supreme Court or the U.S. Supreme Court, the state procedures were inadequate. The panel rejects this, noting:

Connecticut’s Practice Book § 66-6 expressly permits the Appellate Court to “modify or vacate” stay-related orders on motion for review.
Toczek in fact raised due process arguments to the Connecticut Appellate Court during that review process.
Younger does not require availability of immediate state supreme court or U.S. Supreme Court review, nor does it mandate interlocutory review; it requires only an adequate opportunity to raise federal issues before a competent state tribunal.

Citing Juidice, Middlesex, Falco, and McKnight, the court concludes that the lack of immediate high-court review does not defeat abstention so long as an avenue exists—and was utilized—to present constitutional arguments in the state courts.

3) The Court Declines to Reach Other Threshold Issues

Although the defendants also argued Eleventh Amendment immunity, the panel, invoking Steel Co., declines to reach that jurisdictional question after concluding abstention disposes of the case. It notes EX PARTE YOUNG’s prospective-relief exception but finds it unnecessary to analyze because Younger is dispositive.

Impact and Significance

This summary order (non-precedential under Second Circuit Local Rule 32.1.1) provides clear, persuasive guidance on several fronts:

Foreclosure and state-court stay management: Federal courts in the Second Circuit will abstain from granting injunctions that would reconfigure how state courts manage appellate stays in foreclosure proceedings.
Sprint’s categorical approach: Litigants should expect courts to apply Sprint’s third category rigorously when requested relief would affect state-court orders and judgments, particularly docket management and enforcement mechanisms.
Adequate state forum: The availability of Connecticut’s motion-for-review procedure (§ 66-6) to challenge stay orders is sufficient for Younger purposes. The absence of immediate state supreme court review or interlocutory appeal does not make the forum inadequate.
Practical litigation strategy: Federal challenges that seek to undo or preempt state-court stay decisions in ongoing cases will likely fail on abstention grounds. Parties should utilize the state mechanisms (e.g., § 66-6 motions) to present constitutional claims.
Scope beyond foreclosure: The reasoning aligns with prior decisions involving state control over judicial administration (Kaufman) and family law proceedings (Falco), reinforcing a broad reluctance to interfere when relief targets how state courts conduct their business.

Complex Concepts Simplified

Younger abstention: A doctrine of comity and federalism that instructs federal courts not to enjoin ongoing state proceedings in a narrow set of circumstances. After Sprint, those are: (1) criminal cases, (2) certain civil enforcement actions, and (3) civil proceedings implicating state interests in enforcing courts’ orders and judgments.
Sprint’s “third category”: Cases where the requested federal relief would interfere with the state judiciary’s ability to enforce and administer its own orders (e.g., stay orders, fee orders, docket management). Federal courts typically abstain in these cases.
Automatic appellate stay (Connecticut): Under Conn. Practice Book § 61-11(a), enforcing a judgment is automatically stayed for a period to allow an appeal. However, § 61-11(d) authorizes a trial court to terminate or modify that stay under certain conditions, subject to appellate review.
Motion for review (§ 66-6): A procedure in the Connecticut Appellate Court allowing parties to seek review of a trial court’s stay-related order. This is the designated avenue to challenge termination of an appellate stay.
Strict foreclosure (Connecticut): A foreclosure method where, after certain “law days,” title passes to the mortgagee if the mortgagor does not redeem; unlike foreclosure by sale, there is no auction. Enforcement of strict foreclosure judgments often involves stay and scheduling orders.
Adequate opportunity for review: Younger is satisfied if the plaintiff can present federal constitutional arguments somewhere within the state judicial process. It does not require immediate access to the state’s highest court or the U.S. Supreme Court before abstention applies.
Summary order: A non-precedential decision in the Second Circuit. It may be cited pursuant to Fed. R. App. P. 32.1 and Local Rule 32.1.1, but it does not have binding precedential effect.
Eleventh Amendment and EX PARTE YOUNG: States and state officials generally have immunity from suit in federal court, but EX PARTE YOUNG allows suits for prospective relief to stop ongoing violations of federal law. Here, the court did not reach the issue because Younger abstention was dispositive.

Conclusion

The Second Circuit’s decision reaffirms the strong comity principles embedded in Younger, as refined by Sprint. When a federal plaintiff seeks to alter how state courts manage and enforce their own orders—here, termination of automatic appellate stays in foreclosure proceedings—federal courts will abstain. The existence of state procedures (notably Connecticut’s § 66-6 motion for review) to raise constitutional challenges suffices to trigger abstention, even if immediate review by a state supreme court or the U.S. Supreme Court is unavailable.

For litigants, the opinion underscores that challenges to state-court stay determinations belong in the state appellate process, not in federal injunction actions. For courts, it illustrates continued adherence to Sprint’s categorical approach and reinforces the limited role of federal courts in supervising the internal functioning and enforcement mechanisms of state judiciaries.

Key Takeaways

Younger abstention applies to federal suits seeking to reinstate or prevent the termination of state appellate stays in foreclosure cases.
Connecticut’s § 66-6 motion-for-review process provides an adequate avenue to raise due process challenges to stay orders.
Immediate access to the Connecticut Supreme Court or the U.S. Supreme Court is not required for Younger to apply.
Requests for federal injunctions that would dictate how state courts manage enforcement of their judgments will almost invariably be barred under Sprint’s third category.
Because abstention resolved the appeal, the court did not address sovereign immunity or other defenses.