Fair Assessment in Real Estate Assn., Inc. v. McNary

454 U.S. 100, 102 S. Ct. 177, 70 L. Ed. 2d 271, 1981 U.S. LEXIS 6, 50 U.S.L.W. 4017

• Court: Supreme Court of the United States
• Decided: December 1, 1981
• Docket: 80-427
• Status: Published

Opinions

Justice Rehnquist

delivered the opinion of the Court.

In this action we are required to reconcile two somewhat intermittent and conflicting lines of authority as to whether a damages action may be brought under 42 U. S. C. § 1988 to redress the allegedly unconstitutional administration of a state tax system. The United States District Court for the Eastern District of Missouri held that such suits were barred by both 28 U. S. C. § 1841 (Tax Injunction Act) and the principle of comity, and the Court of Appeals for the Eighth Circuit affirmed by an equally divided court sitting en banc.¹ We granted certiorari to resolve a conflict among the Courts of Appeals,² 450 U. S. 1039, and we now affirm. Before setting forth the facts, we think that a description of the past and at times divergent decisions of this Court may shed light upon the proper disposition of this case.

I

This Court, even before the enactment of §1983, recognized the important and sensitive nature of state tax systems and the need for federal-court restraint when deciding cases that affect such systems. As Justice Field wrote for the Court shortly before the enactment of § 1983:

“It is upon taxation that the several States chiefly rely to obtain the means to carry on their respective governments, and it is of the utmost importance to all of them that the modes adopted to enforce the taxes levied should be interfered with as little as possible. Any delay in the proceedings of the officers, upon whom the duty is devolved of collecting the taxes, may derange the operations of government, and thereby cause serious detriment to the public.” Dows v. Chicago, 11 Wall. 108, 110 (1871).

After this Court conclusively decided that federal courts may enjoin state officers from enforcing an unconstitutional state law, Ex parte Young, 209 U. S. 123 (1908), Congress also recognized that the autonomy and fiscal stability of the States survive best when state tax systems are not subject to scrutiny in federal courts. Thus, in 1937 Congress provided:

“The district courts shall not enjoin, suspend or restrain the assessment, levy or collection of any tax under State law where a plain, speedy and efficient remedy may be had in the courts of such State.” 28 U. S. C. § 1341 (hereinafter § 1341 or Act).

This legislation, and the decisions of this Court which preceded it, reflect the fundamental principle of comity between federal courts and state governments that is essential to “Our Federalism,” particularly in the area of state taxation. See, e. g., Matthews v. Rodgers, 284 U. S. 521 (1932); Singer Sewing Machine Co. v. Benedict, 229 U. S. 481 (1913); Boise Artesian Water Co. v. Boise City, 213 U. S. 276 (1909). Even after enactment of § 1341 it was upon this comity that we relied in holding that federal courts, in exercising the discretion that attends requests for equitable relief, may not even render declaratory judgments as to the constitutionality of state tax laws. Great Lakes Dredge & Dock Co. v. Huffman, 319 U. S. 293 (1943).

Contrasted with this statute and line of cases are our holdings with respect to 42 U. S. C. §1983. In 1871, shortly after Justice Field wrote of the vital and vulnerable nature of state tax systems, Congress enacted § 1983 with its familiar language:

“Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress.”

Obviously § 1983 cut a broad swath. By its terms it gave a federal cause of action to prisoners, taxpayers, or anyone else who was able to prove that his constitutional or federal rights had been denied by any State. In addition, the statute made no mention of any requirement that state remedies be exhausted before resort to the federal courts could be had under 28 U. S. C. § 1343.³ The combined effect of this newly created federal cause of action and the absence of an express exhaustion requirement was not immediately realized. It was not until our decision in Monroe v. Pape, 365 U. S. 167 (1961), that § 1983 was held to authorize immediate resort to a federal court whenever state actions allegedly infringed constitutional rights:

“Although the legislation was enacted because of the conditions that existed in the South at that time, it is cast in general language and is as applicable to Illinois as it is to the States whose names were mentioned over and again in the debates. It is no answer that the State has a law which if enforced would give relief. The federal remedy is supplementary to the state remedy, and the latter need not be first sought and refused before the federal one is invoked.” 365 U. S., at 183.

The immediacy of federal relief under § 1983 was reemphasized in McNeese v. Board of Education, 373 U. S. 668 (1963), where the Court stated: “It is immaterial whether [the state official’s] conduct is legal or illegal as a matter of state law. Such claims are entitled to be adjudicated in the federal courts.” Id., at 674 (citation and footnote omitted). And in the unargued per curiam opinion of Wilwording v. Swenson, 404 U. S. 249 (1971), the Court concluded that “[petitioners were . . . entitled to have their actions treated as claims for relief under the Civil Rights Acts, not subject . . . to exhaustion requirements.” Id., at 251. See also Damico v. California, 389 U. S. 416 (1967); Houghton v. Shafer, 392 U. S. 639, 640 (1968); Steffel v. Thompson, 415 U. S. 452, 472-473 (1974).

Thus, we have two divergent lines of authority respecting access to federal courts for adjudication of the constitutionality of state laws. Both cannot govern this case. On one hand, § 1341, with its antecedent basis in the comity principle of Matthews v. Rodgers, supra, and Boise Artesian Water Co. v. Boise City, supra, bars at least federal injunctive challenges to state tax laws. Added to this authority is our decision in Great Lakes Dredge & Dock Co. v. Huffman, supra, holding that declaratory judgments are barred on the basis of comity. On the other hand is the doctrine originating in Monroe v. Pape, supra, that comity does not apply where § 1983 is involved, and that a litigant challenging the constitutionality of any state action may proceed directly to federal court. With this divergence of views in mind, we turn now to the facts of this case, a § 1983 challenge to the administration of state tax laws which implicates both lines of authority. We hold that at least as to such actions, which is all we need decide here, the principle of comity controls.

I — » HH

Petitioner Fair Assessment in Real Estate Association is a nonprofit corporation formed by taxpayers in St. Louis County (County) to promote equitable enforcement of property tax laws in Missouri. Petitioners J. David and Lynn F. Cassilly own real property with recent improvements in the County. Petitioners filed suit under § 1983 alleging that respondents, the County’s Tax Assessors, Supervisors, and Director of Revenue, and three members of the Missouri State Tax Commission, had deprived them of equal protection and due process of law by unequal taxation of real property.

The complaint focuses on two specific practices by respondents. First, petitioners allege that County properties with new improvements are assessed at approximately 3354% of their current market value, while properties without new improvements are assessed at approximately 22% of their current market value. This disparity allegedly results from respondents’ failure to reassess old property on a regular basis, the last general reassessment having occurred in 1960. Second, petitioners allege that property owners who successfully appeal their property assessments, as did the Cassillys in 1977, are specifically targeted for reassessment the next year.

Petitioners have previously sought some relief from respondents’ assessments in state proceedings. In 1975, petitioner David Cassilly and others brought an action in which the State Circuit Court ordered respondent Antonio to reassess all real property in the County. On direct appeal, however, the Missouri Supreme Court reversed on the ground that the State Tax Commission, not the Circuit Court, should supervise the reassessment process. State ex rel. Cassilly v. Riney, 576 S. W. 2d 325 (1979) (en banc). In 1977, the Cassillys appealed the tax assessed on their home to the County Board of Equalization and received a reduction in assessed value from 3314% to 29%. When their home was again assessed at 3314% in 1978, the Cassillys once more appealed to the Board of Equalization. That appeal was pending at the commencement of this litigation.

The Cassillys brought this §1983 action in federal court seeking actual damages in the amount of overassessments from 1975 to 1979, and punitive damages of $75,000 from each respondent. Petitioner Fair Assessment sought actual damages in the amount of expenses incurred in efforts to obtain equitable property assessments for its members. As in all other § 1983 actions, the award of such damages would first require a federal-court declaration that respondents, in administering the state tax, violated petitioners’ constitutional rights.

Ill

As indicated by our discussion in Part I, § 1341 and our comity cases have thus far barred federal courts from granting injunctive and declaratory relief in state tax cases. Because we decide today that the principle of comity bars federal courts from granting damages relief in such cases, we do not decide whether that Act, standing alone, would require such a result.⁴ The correctness of the result in this case is demonstrated by an examination of the pre-Act decisions of this Court, the legislative history of the Act, our post-Act decision in the Great Lakes case, and more recent recognition of the principles of federalism.

A

Prior to enactment of § 1341, virtually all federal cases challenging state taxation sought equitable relief.⁵ Consequently, federal-court restraint in state tax matters was based upon the traditional doctrine that courts of equity will stay their hand when remedies at law are plain, adequate, and complete. See, e. g., Matthews v. Rodgers, 284 U. S. 521 (1932); Singer Sewing Machine Co. v. Benedict, 229 U. S. 481 (1913); Boise Artesian Water Co. v. Boise City, 213 U. S. 276 (1909). Even with this basis in equity law, these cases recognized that the doctrine of equitable restraint was of “notable application,” Boise Artesian Water Co., supra, at 281, and carried “peculiar force,” Matthews, supra, at 525, in suits challenging the constitutionality of state tax laws. Such restraint was particularly appropriate because of the delicate balance between the federal authority and state governments, and the concomitant respect that should be accorded state tax laws in federal court. As the Court in Matthews explained:

“The reason for this guiding principle [of equitable restraint] is of peculiar force in cases where the suit, like the present one, is brought to enjoin the collection of a state tax in courts of a different, though paramount sovereignty. The scrupulous regard for the rightful independence of state governments which should at all times actuate the federal courts, and a proper reluctance to interfere by injunction with their fiscal operations, require that such relief should be denied in every case where the asserted federal right may be preserved without it.” 284 U. S., at 525.⁶

Thus, in 1909 we could state that “[a]n examination of the decisions of this court shows that a proper reluctance to interfere by prevention with the fiscal operations of the state governments has caused it to refrain from so doing in all cases where the Federal rights of the persons could otherwise be preserved unimpaired.” Boise Artesian Water Co., supra, at 282.

B

This policy of equitable restraint based on notions of comity did not completely clear the federal courts of state tax cases. Indeed, the Senate Report on the bill that was to become § 1341 referred to “[t]he existing practice of the Federal courts in entertaining tax-injunction suits against State officers . . . .” S. Rep. No. 1035, 75th Cong., 1st Sess., 2 (1937). An examination of the cases of that era demonstrates, however, that this practice resulted not from a repudiation of the principle of comity, but from federal-court determinations that available state remedies did not adequately protect the federal rights asserted. See, e. g., Grosjean v. American Press Co., 297 U. S. 233, 242 (1936); Gully v. Interstate Natural Gas Co., 82 F. 2d 145 (CA5), cert. denied, 298 U. S. 688 (1936). See also Note, Federal Court Interference with the Assessment and Collection of State Taxes, 59 Harv. L. Rev. 780, 783, n. 13 (1946); Note, The Tax Injunction Act and Suits for Monetary Relief, 46 U. Chi. L. Rev. 736, 744, and nn. 40, 41 (1979).

Congress’ response to this practice of the federal courts— enactment of § 1341 — was motivated in large part by comity concerns. As we said of the Act just last Term:

“The statute ‘has its roots in equity practice, in principles of federalism, and in recognition of the imperative need of a State to administer its own fiscal operations.’ Tully v. Griffin, Inc., 429 U. S. [68,] 73 [(1976)]. This last consideration was the principal motivating force behind the Act: this legislation was first and foremost a vehicle to limit drastically federal district court jurisdiction to interfere with so important a local concern as the collection of taxes. 81 Cong. Rec. 1415 (1937) (remarks of Sen. Bone) . . . .” Rosewell v. LaSalle National Bank, 450 U. S. 503, 522 (1981) (footnote omitted).

Neither the legislative history of the Act nor that of its precursor, 28 U. S. C. § 1342, suggests that Congress intended that federal-court deference in state tax matters be limited to the actions enumerated in those sections. See H. R. Rep. No. 1503, 75th Cong., 1st Sess., 1 (1937); 81 Cong. Rec. 1415 (1937) (remarks of Sen. Bone). Thus, the principle of comity which predated the Act was not restricted by its passage.

C

The post-Act vitality of the comity principle is perhaps best demonstrated by our decision in Great Lakes Dredge & Dock Co. v. Huffman, 319 U. S. 293 (1943). Several Louisiana taxpayers brought an action in Federal District Court seeking a declaratory judgment that the state tax law as applied to them was unconstitutional and void. Although § 1341 was raised as a possible bar to the suit, as it has been raised in this case, “we [found] it unnecessary to inquire whether the words of the statute may be so construed as to prohibit a declaration by federal courts concerning the invalidity of a state tax.” 319 U. S., at 299. Instead, “we [were] of the opinion that those considerations which have led federal courts of equity to refuse to enjoin the collection of state taxes, save in exceptional cases, require[d] a like restraint in the use of the declaratory judgment procedure.” Ibid. Those considerations were, of course, principles of federalism:

“ ‘The scrupulous regard for the rightful independence of state governments which should at all times actuate the federal courts, and a proper reluctance to interfere by injunction with their fiscal operations, require that such relief should be denied in every case where the asserted federal right may be preserved without it.’ ... Interference with state internal economy and administration is inseparable from assaults in the federal courts on the validity of state taxation, and necessarily attends injunctions, interlocutory or final, restraining collection of state taxes. These are the considerations of moment which have persuaded federal courts of equity to deny relief to the taxpayer . . . .” Id., at 298 (quoting Matthews v. Rodgers, 284 U. S., at 525).

The Court’s reliance in Great Lakes upon the necessity of federal-court respect for state taxing schemes demonstrates not only the post-Act vitality of the comity principle, but also its applicability to actions seeking a remedy other than in-junctive relief. The focus was not on the specific form of relief requested, but on the fact that “in every practical sense [it] operate[d] to suspend collection of the state taxes until the litigation [was] ended.” 319 U. S., at 299. As will be seen below, the relief sought in this case would have a similarly disruptive effect.

D

The principle of comity has been recognized and relied upon by this Court in several recent cases dealing with matters other than state taxes. Its fullest articulation was given in the now familiar language of Younger v. Harris, 401 U. S. 37 (1971), a case in which we held that traditional principles of equitable restraint bar federal courts from enjoining pending state criminal prosecutions except under extraordinary circumstances:

“Th[e] underlying reason for restraining courts of equity from interfering with criminal prosecutions is reinforced by an even more vital consideration, the notion of ‘comity,’ that is, a proper respect for state functions, a recognition of the fact that the entire country is made up of a Union of separate state governments, and a continuance of the belief that the National Government will fare best if the States and their institutions are left free to perform their separate functions in separate ways. . . . [T]he concept [represents] a system in which there is sensitivity to the legitimate interests of both State and National Governments, and in which the National Government, anxious though it may be to vindicate and protect federal rights and federal interests, always endeavors to do so in ways that will not unduly interfere with the legitimate activities of the States. It should never be forgotten that this slogan, ‘Our Federalism,’ born in the early struggling days of our Union of States, occupies a highly important place in our Nation’s history and its future.” Id., at 44-45.

The principles of federalism recognized in Younger have not been limited to federal-court interference in state criminal proceedings, but have been extended to some state civil actions. E. g., Huffman v. Pursue, Ltd., 420 U. S. 592 (1975). Although these modern expressions of comity have been limited in their application to federal cases which seek to enjoin state judicial proceedings, a limitation which we do not abandon here, they illustrate the principles that bar petitioners’ suit under § 1983. As we said in Rosewell, swpra, “the reasons supporting federal noninterference [with state taxation] are just as compelling today as they were in 1937.” 450 U. S., at 527. As will be seen in the next part, petitioners’ § 1983 action would be no less disruptive of Missouri’s tax system than would the historic equitable efforts to enjoin the collection of taxes, efforts which were early held barred by considerations of comity.

IV

In arguments primarily addressed to the applicability of the Act, petitioners contend that damages actions are inherently less disruptive of state tax systems than injunctions or declaratory judgments, and therefore should not be barred by prior decisions of this Court. Petitioners emphasize that their § 1983 claim seeks recovery from individual state officers, not from state coffers, and that the doctrine of qualified immunity will protect such officers’ good-faith actions and will thus avoid chilling their administration of the Missouri tax scheme.

We disagree. Petitioners will not recover damages under § 1983 unless a district court first determines that respondents’ administration of the County tax system violated petitioners’ constitutional rights. In effect, the district court must first enter a declaratory judgment like that barred in Great Lakes. We are convinced that such a determination would be fully as intrusive as the equitable actions that are barred by principles of comity.⁷ Moreover, the intrusiveness of such §1983 actions would be exacerbated by the nonexhaustion doctrine of Monroe v. Pape, 365 U. S. 167 (1961). Taxpayers such as petitioners would be able to invoke federal judgments without first permitting the State to rectify any alleged impropriety.

In addition to the intrusiveness of the judgment, the very maintenance of the suit itself would intrude on the enforcement of the state scheme. As the District Court in this case stated:

“To allow such suits would cause disruption of the states’ revenue collection systems equal to that caused by anticipatory relief. State tax collection officials could be summoned into federal court to defend their assessments against claims for refunds as well as prayers for punitive damages, merely on the assertion that the tax collected was willfully and maliciously discriminatory against a certain type of property. Allowance of such claims would result in this Court being a source of appellate review of all state property tax classifications.” 478 F. Supp. 1231, 1233-1234 (1979).

This intrusion, although undoubtedly present in every § 1983 claim, is particularly highlighted by the facts of this case. Defendants are not one or two isolated administrators, but virtually every key tax official in St. Louis County. They include the County Executive, the Director of Revenue, the Tax Assessor, and three supervising members of the State Tax Commission. In addition, the actions challenged in the complaint — unequal assessment of new and old property and retaliatory assessment of property belonging to those who successfully appeal to the Board of Equalization — may well be the result of policies or practicalities beyond the control of any individual officer. For example, failure annually to reassess old property may well result from a practical allocation of limited resources. In addition, according to respondents’ attorney at oral argument, Missouri law requires that all property, including property which belongs to those who successfully appeal to the Board of Equalization, be assessed at 3314% of market value. Thus, a judicial determination of official liability for the acts complained of, even though necessarily based upon a finding of bad faith, would have an undeniable chilling effect upon the actions of all County officers governed by the same practicalities or required to implement the same policies. There is little doubt that such officials, faced with the prospect of personal liability to numerous taxpayers, not to mention the assessment of attorney’s fees under 42 U. S. C. §1988, would promptly cease the conduct found to have infringed petitioners’ constitutional rights, whether or not those officials were acting in good faith. In short, petitioners’ action would “in every practical sense operate to suspend collection of the state taxes . . . ,” Great Lakes, 319 U. S., at 299, a form of federal-court interference previously rejected by this Court on principles of federalism.

Y

This case is therefore controlled by principles articulated even before enactment of § 1983 and followed in later decisions such as Matthews and Great Lakes. The recovery of damages under the Civil Rights Act first requires a “declaration” or determination of the unconstitutionality of a state tax scheme that would halt its operation. And damages actions, no less than actions for an injunction, would hale state officers into federal court every time a taxpayer alleged the requisite elements of a § 1983 claim. We consider such interference to be contrary to “[t]he scrupulous regard for the rightful independence of state governments which should at all times actuate the federal courts.” Matthews, 284 U. S., at 525.

Therefore, despite the ready access to federal courts provided by Monroe and its progeny, we hold that taxpayers are barred by the principle of comity from asserting § 1983 actions against the validity of state tax systems in federal courts. Such taxpayers must seek protection of their federal rights by state remedies, provided of course that those remedies are plain, adequate, and complete,⁸ and may ultimately seek review of the state decisions in this Court. See Huffman v. Pursue, Inc., 420 U. S., at 605; Matthews v. Rodgers, supra, at 526.

The adequacy of available Missouri remedies is not at issue in this case. The District Court expressly found “that [petitioners] have means to rectify what they consider an unjust situation through the state’s own processes,” 478 F. Supp., at 1234, and petitioners do not contest this finding. In addition, the Missouri Supreme Court has expressly held that plaintiffs such as petitioners may assert a § 1983 claim in state court. See, e. g., Stafford v. Muster, 582 (1979); Shapiro v. Columbia Union National Bank & Trust Co., 576 S. W. 2d 310 (1978).

Accordingly, the judgment of the Court of Appeals is

Affirmed.

1 Fair Assessment in Real Estate Assn., Inc. v. McNary, 478 F. Supp. 1231 (1979), aff’d, 622 F. 2d 415 (1980).

2 Compare Fulton Market Storage Co. v. Cullerton, 582 F. 2d 1071 (CA7 1978), cert. denied, 439 U. S. 1121 (1979), with Fair Assessment in Real Estate Assn., Inc. v. McNary, supra; Ludwin v. City of Cambridge, 592 F. 2d 606 (CA1 1979); and Bland v. McHann, 463 F. 2d 21 (CA5 1972), cert. denied, 410 U. S. 966 (1973).

3 We held in Chapman v. Houston Welfare Rights Organization, 441 U. S. 600 (1979), that 28 U. S. C. § 1343, the jurisdictional counterpart of 42 U. S. C. § 1983, was narrower in scope than the latter. Because there can be no doubt that a claim of denial of due process or equal protection under the Fourteenth Amendment, which these petitioners asserted, would come under the narrower construction of § 1343 adopted by the Court in Chapman, supra, it is unnecessary to pursue here the difference between § 1983 and § 1343.

4 The result we reach today was foreshadowed by our decision last Term in Rosewell v. LaSalle National Bank, 450 U. S. 503 (1981), wherein we stated that “even where the Tax Injunction Act would not bar federal-court interference in state tax administration, principles of federal equity may nevertheless counsel the withholding of relief. See Great Lakes Dredge & Dock Co. v. Huffman, 319 U. S. 293, 301 (1943).” Id., at 525-526, n. 33. We need not decide in this case whether the comity spoken of would also bar a claim under § 1983 which requires no scrutiny whatever of state tax assessment practices, such as a facial attack on tax laws colorably claimed to be discriminatory as to race.

5 Of course, the Court had not yet broadly interpreted the Civil Rights Act to permit federal damages actions for state violations of constitutional rights, brought prior to exhaustion of state remedies. See Monroe v. Pape, 365 U. S. 167 (1961). The closest pre-Act case to a federal damages action was a suit for refund of state taxes allegedly assessed in violation of the Fourteenth Amendment. First National Bank v. Board of County Commissioners, 264 U. S. 450 (1924). Consistent with the federal-court deference for state tax matters of which we speak today, the Court held that the action was barred by the parties’ failure to exhaust their available state remedies. Id., at 456. Although declaratory actions were available before 1937, they were seldom used. See Note, Federal Declaratory Judgments on the Validity of State Taxes, 50 Yale L. J. 927, 929-930, and n. 14 (1941).

6 Justice BRENNAN has cogently explained the reasons behind federal-court deference for state tax administration:

“The special reasons justifying the policy of federal noninterference with state tax collection are obvious. The procedures for mass assessment and collection of state taxes and for administration and adjudication of taxpayers’ disputes with tax officials are generally complex and necessarily designed to operate according to established rules. State tax agencies are organized to discharge their responsibilities in accordance with the state procedures. If federal declaratory relief were available to test state tax assessments, state tax administration might be thrown into disarray, and taxpayers might escape the ordinary procedural requirements imposed by state law. During the pendency of the federal suit the collection of revenue under the challenged law might be obstructed, with consequent damage to the State’s budget, and perhaps a shift to the State of the risk of taxpayer insolvency. Moreover, federal constitutional issues are likely to turn on questions of state tax law, which, like issues of state regulatory law, are more properly heard in the state courts.” Perez v. Ledesma, 401 U. S. 82, 128, n. 17 (1971) (concurring in part and dissenting in part).

7 0ther federal courts have reached this same conclusion. For example, in Advertiser Co. v. Wallace, 446 F. Supp. 677, 680 (MD Ala. 1978), the court concluded that “[although perhaps less coercive than anticipatory relief and less intrusive than a refund, the damage award plaintiff seeks, especially its request for punitive damages, still is designed to deter collection of the taxes now being assessed by defendants.” And the court in Evangelical Catholic Communion, Inc. v. Thomas, 373 F. Supp. 1342, 1344 (Vt. 1973), correctly stated:

“It is elementary that constitutional rights must be found to have been abridged in order for damages to be recovered in a civil rights action. Thus the plaintiffs in this action cannot recover damages without a determination by this court that the taxation of their Newbury property was effected in violation of their constitutional rights. If we were to make such a determination, we would, in effect, be issuing a declaratory judgment regarding the constitutionality of the tax levied on the plaintiffs. As the court is prohibited from issuing such a declaratory judgment, . . . the court is also precluded as a matter of law from adjudicating the plaintiffs’ damages claims.”

8 We discern no significant difference, for purposes of the principles recognized in this case, between remedies which are “plain, adequate, and complete,” as that phrase has been used in articulating the doctrine of equitable restraint, and those which are “plain, speedy and efficient,” within the meaning of §1341. See, e. g., Tully v. Griffin, Inc., 429 U. S. 68, 73-74 (1976); Hillsborough v. Cromwell, 326 U. S. 620, 622-623 (1946); Great Lakes Dredge & Dock Co. v. Huffman, 319 U. S., at 297-299; Matthews v. Rodgers, 284 U. S., at 525-526. Both phrases refer to the obvious precept that plaintiffs seeking protection of federal rights in federal courts should be remitted to their state remedies if their federal rights will not thereby be lost. Numerous federal decisions have treated the adequacy of state remedies, and it is to that body of law that federal courts should look in seeking to determine the occasions for the comity spoken of today.