The United States District Court for the Eastern District of Pennsylvania has held that the court need not abstain from approving a consent agreement between the Commonwealth and the Pennsylvania Association for Retarded Children, although the statutes challenged under the equal protection clause and under state law were unclear.
The Pennsylvania Association for Retarded Children v. Pennsylvania, 343 F. Supp. 279 (E.D. Pa. 1972).
Gary N. Moskovitz,
Federal Courts - Doctrine of Abstention,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol12/iss1/14