Today, courts and commentators treat the Younger doctrine as a central rule with several enumerated exceptions. This prevailing view is incorrect. An analysis of the exceptions to the Younger abstention doctrine demonstrates that the exceptions are merely applications of the equity and comity principles that the Younger Court used to justify abstention. If federal courts blindly apply the exceptions to Younger v. Harris, as if the exceptions have independent legal justifications, they risk incorrectly determining the very cases that Younger doctrine requires them to avoid. Instead, federal courts should always consider whether abstention is mandated under the principles of equity and comity.
Hillier, Drew Alan, "The Necessity of an Equity and Comity Analysis in Younger Abstention Doctrine Note" (2014). Connecticut Law Review. 262.