Younger abstention applied to District of Columbia

Although not related to criminal law, I think you may find it interesting -particularly those of us in Puerto Rico with our never ending debate on status politics - that the U.S. Court of Appeals for the D.C. Circuit had, up until now, avoided deciding whether the Younger abstention doctrine applied to the District of Columbia. The Court has now decided it does. See JMM Corp. v. District of Columbia and D.C. Department of Consumer and Regulatory Affairs, No. 03-7057 (D.C. Cir. August 17, 2004). The tough issue was on the federalism concerns of Younger abstention.