Smith & Wesson Brands, Inc. v. Att’y Gen. of N.J.

The Third Circuit vacated an order from the District Court that dismissed Smith & Wesson’s federal civil rights complaint. The New Jersey Attorney General is investigating the gun manufacturer for potential consumer-fraud violations. As part of that investigation, the Attorney General issued a subpoena seeking documents related to the company’s advertisements in New Jersey. Instead of producing the documents, Smith & Wesson filed a complaint in the District of New Jersey under 42 U.S.C. § 1983, alleging the subpoena violated the First, Second, Fourth, Fifth, and Fourteenth Amendments. While the parties engaged in contentious litigation over the subpoena in state court, the District Court dismissed the federal action based on Younger abstention. The Third Circuit held that the subpoena enforcement action was not quasi-criminal. The Court also held that the document production order was not uniquely in furtherance of the state courts’ ability to perform their judicial functions. In light of those two findings, the Court held that the District Court violated its virtually unflagging obligation to exercise the jurisdiction given.

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