THIS NOTE ANALYZES THE DIFFERENT CIRCUIT COURT INTERPRETATIONS OF THE APPLICABILITY OF YOUNGER TO THE GRANTING OF RELIEF NOT DIRECTED AT, OR INTENDING TO HALT, THE STATE CRIMINAL PROSECUTION, AS WELL AS THE CONFLICTING SUPREME COURT DECISIONS. AN EXAMINATION OF THE PRE- 1974 DECISIONS IN THIS AREA, REVEALS THAT THE THIRD, FOURTH, FIFTH, AND SEVENTH CIRCUITS FAVORED RESTRICTING YOUNGER TO INJUNCTIONS AIMED AT HALTING STATE PROCEEDINGS, HOLDING YOUNGER INAPPLICABLE TO RELIEF INVOLVING INJURY TO FEDERAL CONSTITUTIONAL RIGHTS. THE SECOND AND NINTH CIRCUITS, HOWEVER, WERE FOUND TO VIEW YOUNGER AS APPLICABLE TO THE WHOLE STATE CRIMINAL PROCESS AND NOT MERELY TO STATE CRIMINAL PROCEEDINGS. IN THE 1974 CASE OF O'SHEA V. LITTLETON, THE SUPREME COURT INDICATED THAT IT FAVORED A BROAD APPLICATION OF THE YOUNGER DOCTRINE TO ENCOMPASS COLLATERAL MATTERS. A YEAR LATER IN GERSTEIN V. PUGH, HOWEVER, IN REVIEWING THE VALIDITY OF A FEDERAL INJUNCTION REQUIRING A PROBABLE CAUSE HEARING IN STATE CRIMINAL ACTIONS, THE COURT INDICATED ITS APPROVAL, OF A MORE LIMITED APPLICATION. THE AUTHOR ARGUES THAT WITHOUT CLEAR SUPREME COURT DIRECTION IN THIS AREA, THE CIRCUIT COURTS WILL REMAIN DIVIDED ALONG PRE-O'SHEA LINES, ALTHOUGH THE NARROW INTERPRETATION OF YOUNGER WILL BECOME MORE DIFFICULT TO DEFEND. IT IS ALSO POINTED OUT THAT THE CONTINUED BROAD APPLICATION OF YOUNGER WOULD EFFECTIVELY BAR PLAINTIFFS CHALLENGING ANY ASPECT OF THE STATE'S CRIMINAL SYSTEM (EVEN STATE DEPRIVATION OF FEDERAL CONSTITUTIONAL RIGHTS) FROM ACCESS TO FEDERAL COURT. THE AUTHOR RECOMMENDS THAT THE SUPREME COURT LIMIT O'SHEA TO VAGUE ALLEGATIONS OF DISCRIMINATING STATE CRIMINAL PROCEDURES, AND PROVIDE MINIMAL STANDARDS AND GUIDELINES FOR EQUITABLE RELIEF.