In the case of Boyle, Judge, et al. v. Landry et al., 1970, a group of African-American residents in Louisiana filed a lawsuit against local officials for allegedly suppressing their constitutional rights through racial discrimination and violence. The Supreme Court ruled that federal courts should abstain from interfering with ongoing state criminal proceedings unless there is proven bad faith harassment or prosecution under unconstitutional statutes. This decision was based on the principle of comity which respects the balance between state and federal authority within our system of government. In this particular case, it was determined that no such proof existed to warrant interference by federal courts into ongoing state matters.

In the dissenting opinion for Boyle, Judge, et al. v. Landry et al., Justice Brennan disagreed with the majority's decision to reverse and remand the case back to District Court. He argued that there was sufficient evidence of a pattern of police misconduct in violation of constitutional rights which should have been addressed by an injunction from federal courts as per 42 U.S.C §1983. The statute allows citizens to seek protection from local authorities who deprive them of their civil rights under color of law, but according to Brennan, this right was denied by sending it back down without addressing these issues first at Supreme Court level. Furthermore, he criticized the majority’s reliance on Younger v Harris (1971) abstention doctrine because he believed it did not apply in this situation where state proceedings were not pending when federal action commenced.