QUINN v. KIBODEAUX (2021)

United States Court of Appeals, Ninth Circuit.2021-02-22No. No. 20-36070

Summary · law.co

Holding. The court affirmed the district court's dismissal of Quinn's action under the Younger abstention doctrine because the federal lawsuit sought to interfere with pending state family court proceedings.

Roger Quinn filed a federal civil rights lawsuit under 42 U.S.C. § 1983 challenging conduct related to a family court proceeding. The district court dismissed his action, and Quinn appealed representing himself. The appellate court upheld the dismissal based on the Younger abstention doctrine, which requires federal courts to refrain from interfering with ongoing state court proceedings, particularly those involving child custody matters.

The court applied established precedent holding that when a federal lawsuit would have the practical effect of enjoining state proceedings, federal courts must abstain from hearing the case. The timing of when abstention applies is measured from the date the federal action is filed. Quinn's request for a temporary injunction to halt the case pending appeal was also rejected.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

Application of Younger abstention doctrine in federal civil rights cases
Federal court jurisdiction over challenges to ongoing state court family proceedings
Whether federal courts must abstain when federal action would enjoin state proceedings

Procedural posture

Quinn appealed pro se from the district court's dismissal of his § 1983 action challenging a state family court proceeding.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

MEMORANDUM **

Roger Quinn appeals pro se from the district courts judgment dismissing his 42 U.S.C. § 1983 action alleging claims related to a family court proceeding. We have jurisdiction under 28 U.S.C. § 1291. We review de novo the application of abstention under Younger v. Harris, 401 U.S. 37, 91 S.Ct. 746, 27 L.Ed.2d 669 (1971). ReadyLink Healthcare, Inc. v. State Comp. Ins. Fund, 754 F.3d 754, 758 (9th Cir. 2014). We affirm.

The district court properly dismissed Quinns action as barred under the Younger abstention doctrine because federal courts are required to abstain from interfering with pending state court proceedings where “the federal action would have the practical effect of enjoining the state proceedings.” Id. at 758-59 (setting forth requirements for Younger abstention in civil cases, and explaining that “the date for determining whether Younger applies is the date the federal action is filed” (citation and internal quotation marks omitted)); H.C. ex rel. Gordon v. Koppel, 203 F.3d 610, 612-14 (9th Cir. 2000) (explaining that Younger abstention is appropriate where federal action seeks to challenge ongoing state child custody proceedings).

Quinns motion for temporary injunction pending appeal (Docket Entry Nos. 9 and 10) is denied.

AFFIRMED.