Background
The American Academy of Pediatrics sued Florida Attorney General James Uthmeier in the Northern District of Illinois and obtained a preliminary injunction preventing him from litigating claims under Florida law in Florida state court. The district court relied on the bad-faith exception to Younger abstention.
While the appeal was pending, the Academy moved to dismiss its federal complaint, and the district court granted that motion. The district court also indicated that it was willing to vacate its preliminary injunction, leaving the Seventh Circuit to address how the now-moot appeal should be concluded.
The Court’s Holding
Sitting en banc and acting per curiam, the Seventh Circuit remanded the case and authorized the district court to vacate its preliminary injunction under Federal Rule of Appellate Procedure 12.1(b). The court explained that once the injunction is vacated, no appealable order will remain and the appeal will be dismissed for lack of jurisdiction.
The court did not decide whether the preliminary injunction was proper or define the scope of Younger’s bad-faith exception. Separate writings debated those issues, but all judges agreed that the controversy was moot, the injunction should be vacated, and the appeal should end.
Key Takeaways
- The Seventh Circuit remanded so the district court could vacate the preliminary injunction after the plaintiff voluntarily dismissed its complaint.
- Once the injunction is vacated, the appeal will be dismissed for lack of jurisdiction because no appealable order will remain.
- The en banc court left unresolved the merits of the injunction and the proper scope of Younger’s bad-faith exception.
Why It Matters
The disposition prevents a preliminary injunction from remaining in place after the underlying federal action and appellate controversy became moot. It also avoids an advisory ruling on contested First Amendment, federalism, and abstention questions.
The separate opinions nevertheless highlight an ongoing divide over when federal courts may invoke Younger’s bad-faith exception to enjoin state enforcement proceedings—a question the Seventh Circuit reserved for a future live controversy.