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Davis v. McDonnell

United States District Court, C.D. California, Western Division

December 31, 2014

KAMAU A. DAVIS, Petitioner,
JIM McDONNELL, Los Angeles County Sheriff, Respondent.


JESUS G. BERNAL, District Judge.


Kamau A. Davis ("Petitioner") alleges that he is currently being detained at the Los Angeles County Jail during pretrial proceedings, involving unspecified criminal charges, in the California Superior Court for Los Angeles County (case no. NA091042) ("Los Angeles Superior Court").

On December 10, 2014, Petitioner filed the pending Petition for Writ of Habeas Corpus pursuant to 28 U.S.C. § 2241 ("Petition"). The Petition and attached memorandum raise three claims, two alleging that the prosecution has failed to disclose discovery, and one alleging a Fourth Amendment violation. (Pet. at 3-4; Memorandum of Law in Support of Writ of Habeas Corpus § 2241 ("Mem.") [2] at 5-13.)

For the reasons discussed below, the Court finds the Petition is subject to summary dismissal under Younger v. Harris, 401 U.S. 37, 91 S.Ct. 746 (1971), commonly referred to as the Younger abstention doctrine.


2.1 Younger Abstention Doctrine

Under the Younger abstention doctrine, "a federal court will not intervene in a pending state criminal proceeding absent extraordinary circumstances where the danger of irreparable harm is both great and immediate." Id. at 45. This is because the state is "charged with the duty of prosecuting offenders against the laws of [that] state, and must decide when and how this is to be done, " and therefore, "[t]he accused should first set up and rely upon his defense in the state courts, ... unless it plainly appears that this course would not afford adequate protection." Id. "[O]nly in the most unusual circumstances is a defendant entitled to have federal interposition by way of injunction or habeas corpus until after the jury comes in, judgment has been appealed from and the case concluded in the state courts." Drury v. Cox, 457 F.2d 764, 764-65 (9th Cir. 1972). Consequently, it is well-settled that, absent extraordinary circumstances, "abstention in favor of state judicial proceedings is required if the state proceedings (1) are ongoing, (2) implicate important state interests, and (3) provide the [petitioner] an adequate opportunity to litigate federal claims." Canatella v. California, 404 F.3d 1106, 1109-10 (9th Cir. 2005); see also Middlesex County Ethics Comm. v. Garden State Bar Ass'n, 457 U.S. 423, 432, 437, 102 S.Ct. 2515 (1982).

Here, all three criteria for Younger abstention are met.

First, Petitioner's criminal proceeding in the Los Angeles Superior Court is ongoing in that he appears to be in the pretrial stage and his claims involve pretrial discovery and Fourth Amendment issues.

Second, the ongoing criminal proceeding implicates important state interests. See Kelly v. Robinson, 479 U.S. 36, 49, 107 S.Ct. 353 (1986) ("[T]he States' interest in administering their criminal justice systems free from federal interference is one of the most powerful of the considerations that should influence a court considering equitable types of relief.") ( citing Younger, 401 U.S. at 44-45); see also Rose v. Mitchell, 443 U.S. 545, 585, 99 S.Ct. 2993 (1979) ("Nowhere has a proper respect for state functions been more essential to our federal system than in the administration of criminal justice. This Court repeatedly has recognized that criminal law is primarily the business of the States, and that absent the most extraordinary circumstances the federal courts should not interfere with the States' administration of that law.") (citations and internal quotation marks omitted).

As for the third factor, "[w]here vital state interests are involved, a federal court should abstain unless state law clearly bars the interposition of the constitutional claims." Middlesex County Ethics Comm., 457 U.S. at 432 (citation and internal quotation marks omitted); see also Pennzoil Co. v. Texaco, Inc., 481 U.S. 1, 15, 107 S.Ct. 1519 (1987) ("[A] federal court should assume that state procedures will afford an adequate remedy, in the absence of unambiguous authority to the contrary."). Here, Petitioner has not alleged nor shown that state law prohibits attempts to compel discovery or assert his Fourth Amendment rights. Further, Petitioner has ostensibly raised these claims at each level of the state courts, and the mere fact the state courts rejected them does not mean he was provided an inadequate opportunity to litigate them. Middlesex County Ethics Comm., 457 U.S. at 432; Pennzoil Co., 481 U.S. at 15.

Further, to the extent the state courts issued final orders or judgments denying Petitioner's claims, this Court is alternatively barred from reviewing them by the Rooker-Feldman doctrine, which provides that federal district courts lack jurisdiction to exercise appellate review over final state court judgments. See Rooker v. Fidelity Trust Co., 263 U.S. 413, 44 S.Ct. 149 (1923); D.C. Ct. of Appeals v. Feldman, 460 U.S. 462, 103 S.Ct. 1303 (1983); Henrichs v. Valley View Development, 474 F.3d 609, 613 (9th Cir. 2007).

Regardless, absent an exception to the Younger abstention doctrine, the Court finds Younger bars this Court from jurisdiction to consider Petitioner's claims. Canatella, ...

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