The U.S. Court of Appeals for the Second Circuit decided Friday against federal court intervention in a challenge implicating the New York state court system’s handling of certain surrogate’s court guardianship proceedings for failing to provide vulnerable people with proper protections.
The panel of Circuit Judges José Cabranes, Gerard Lynch and Denny Chin opted to uphold the decision by U.S. District Judge Alvin Hellerstein of the Southern District of New York to abstain in the suit. Brought by Disability Rights New York against the state court system, the litigation sought federal intervention to address the alleged constitutional violations faced by two different groups in New York Surrogate’s Courts.
The suit claimed individuals with intellectual and developmental disabilities involved in guardianship proceedings under Article 17A of the Surrogate’s Court Procedure Act were being deprived of the more robust procedures of Article 81 of the New York Mental Hygiene Law that primarily deals with guardianship proceedings for elderly, disabled adults.
Hellerstein agreed with attorneys for the state that the district court should abstain from the case under the U.S. Supreme Court decisions in 1971’s Younger v. Harris and the subsequent decision in 1974’s O’Shea v. Littleton, both of which place limits on federal intervention into state courts’ business.
On appeal, the panel upheld the district court’s decision, relying on the same progeny of cases. O’Shea in particular informed the panel’s opinion, as it expanded the deference to review of court proceedings even absent parallel litigation at the state level. Additionally, O’Shea has been extended into the civil realm in the context of operation in state courts, the panel noted.
O’Shea has played a role in guarding New York’s courts against intrusion by their sister federal courts, the panel noted. In Kaufman v. Kaye the circuit abstained from declaring the state court’s system for assigning cases among panels of appellate judges in violation of the U.S. Constitution, out of concern of running afoul of the kinds of piecemeal interruptions of state proceedings condemned in O’Shea.
“Ongoing, case‐by‐case oversight of state courts, like the New York Surrogateʹs Court, is exactly the sort of interference OʹShea seeks to avoid,” the panel wrote.
Disability Rights New York argued, among a number of points, that federal courts have often ruled on state statutes as being unconstitutional, citing the landmark same-sex marriage ruling in Obergefell v. Hodges and the Sixth Amendment protections in sentencing of Blakely v. Washington.
The difference, the panel found, was DRNY sought a “more substantial invasion of the state courts’ domain” by pre-emptively reviewing a state court procedure, while the other citations challenged the substance of state statutes and appealed a final judgment of the state courts, respectively.
A spokeswoman for the disability rights group said it was still reviewing the decision and had no comment.
New York State Unified Court System spokesman Lucian Chalfen said in a statement, “The courts apply the statutes as enacted by the legislature and if the federal courts invalidate them we will act accordingly.”