S.D.Cal.: 1983 suit against facts of detention barred by Younger abstention

Plaintiff’s claims in substantial part attack the facts of his current detention, and it’s barred by Younger abstention. Mondragon v. County of San Diego, 2020 U.S. Dist. LEXIS 155166 (S.D. Cal. Aug. 26, 2020)*:

As stated above, there are few facts in Plaintiff’s Complaint but he appears to challenge the basis for his current detention and ongoing state criminal proceeding. To the extent that Plaintiff is currently in the process of facing state criminal charges and requests that this Court intervene in the state court’s decisions, the Court declines to do so. A federal court cannot interfere with ongoing state criminal proceedings by granting injunctive relief absent a showing of the state’s bad faith or harassment, or a showing that the statute challenged is “flagrantly and patently violative of express constitutional prohibitions.” Younger v. Harris, 401 U.S. 37, 46, 53-54 (1971).

Younger abstention is appropriate if four criteria are met: (1) state judicial proceedings are ongoing; (2) the state proceedings implicate an important state interest; (3) the state proceedings offer an adequate opportunity to litigate federal questions; and (4) the federal court action would “enjoin the proceeding or have the practical effect of doing so, i.e., would interfere with the state proceeding in a way that Younger disapproves.” San Jose Silicon Valley Chamber of Commerce PAC v. City of San Jose, 546 F.3d 1087, 1092 (9th Cir. 2008). Here, because it appears that Plaintiff has ongoing criminal proceedings in state court, abstention as to Plaintiff’s Fourth Amendment and due process claims pursuant to the Younger doctrine is warranted.