Woodfeathers, Inc. v. Washington County

In August 1995, Washington County, Oregon, (the County) cited Woodfeathers, Inc., for violating its solid waste ordinance by transporting and disposing of solid waste without a County certificate. Proceedings began in state court leading eventually to a trial in which Woodfeathers was found in violation, followed by an appeal by Woodfeathers. While the state court proceedings were pending, Woodfeathers, in February 1996, filed this action in the district court, challenging the constitutionality of the ordinance and seeking relief against its enforcement. The district court refused to abstain and enjoined enforcement of the ordinance, holding it preempted by federal law and invalid under the Commerce Clause. Because we find that the district court erred in failing to abstain under Younger v. Harris, 401 U.S. 37 , 91 S.Ct. 746 , 27 L.Ed.2d 669 (1971), we reverse.

FACTS AND PROCEDURAL HISTORY

Woodfeathers, Inc., is an Oregon corporation that sells and delivers building materials to roofing contractors. It also offers its customers a drop box service for disposal of the debris created by the removal of the old roof. Woodfeathers delivers a box to the construction site and when…