Miles v. Wesley

Summarized by:

  • Court: 9th Circuit Court of Appeals Archives
  • Area(s) of Law: Civil Procedure
  • Date Filed: 09-08-2015
  • Case #: 13-55620
  • Judge(s)/Court Below: Circuit Judge Nguyen for the Court; Circuit Judge Fernandez and Parker
  • Full Text Opinion

Federal court abstention is appropriate when intervention into state court proceedings would be intrusive and unworkable.

The Los Angeles County Superior Court (LASC) faced major budget cuts and as a result made large consolidations to remain in compliance with their reduced budget. Brenda Miles, Dane Sullivan, and multiple non-profit organizations, together Plaintiffs, challenged the consolidation of tenant evictions into hub courts. Plaintiffs argued that because individuals with disabilities and minorities are disproportionately renters who rely on public transportation closing courtrooms and creating specialized hubs would have a disparate impact on their communities. The district court dismissed the case on federal abstention grounds. On appeal, the Ninth Circuit affirmed the district court, rendering that abstention was appropriate under O’Shea v. Littleton. The panel explained that previous case law was correctly applied that principles of federalism were prevalent here, and that this is a fact-sensitive determination. Here, the allowance of judicial resources would be to the detriment of the criminal, juvenile, family, or mental health law issues. With the major budget cuts LSAC was facing, the federal court will not overstep its boundaries with regard to infringing on the independence of state judiciaries. Intervention would be an unworkable and intrusive. AFFIRMED.

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