The United States Court of Appeals for the Third Circuit has held that the Younger abstention doctrine does not bar a federal court from entertaining a civil rights action seeking injunctive relief against an ongoing state quiet title action since the state had not initiated the underlying state proceeding.
Johnson v. Kelly, 583 F.2d 1242 (3d Cir. 1978).
Jerry S. McDevitt,
Constitutional Law - Civil Rights Actions - Federal Court Review of State Statutes - Abstention,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol17/iss3/17