narrowly limited to facts like those in Dombrowski. Other scholars have even asserted that the possible range of cases which would fit the Dombrowski model and allow an exception to the no-injunction rule is so limited as to be an "empty universe." Patently unconstitutional law: in no case since Younger was decided has the Supreme court found there to exist a patently unconstitutional law sufficient to justify a federal court injunction against state court proceedings. The Court has specifically declined to find such patent unconstitutionality in at least one case (Trainor v. Hernandez) Inadequate state forum: the Supreme Court has found the state forum in question to be inadequate on a small number of occasions. See also Abstention doctrine Anti-Injunction Act (1793) References External links United States Supreme Court cases United States Supreme Court cases of the Burger Court United States Constitution Article Three case law United States abstention case law 1971 in United States case law