E.T. v. Cantil-Sakauye

The abstention doctrine does not allow the Court to adjudicate complaints were the relief sought would require the Federal Court to investigate into the administration and operation of the state’s juvenile court system.

Plaintiffs filed a class action lawsuit under 42 U.S.C. § 1983 on behalf of themselves and around 5,100 foster children in Sacramento County. The complaint alleged procedural and substantive due process violations. The plaintiffs’ claimed that heavy caseloads prevented the juvenile court system from fairly and adequately hearing their cases, and prevented court-appointed attorneys from providing them with effective representation. They sought a declaratory judgment, injunctive relief preventing future violations, and an order to provide adequate funds and resources to comply with recommended caseloads. The Ninth Circuit affirmed the district courts dismissal on abstention grounds under Younger and O’Shea. The Court held that adjudication of the plaintiffs claim would violate the abstention doctrine because a declaratory judgment that the operation was unconstitutional would pave the way for future request for more detailed investigation, and would require a substantial case-by-case investigation intruding upon the state’s administration of the court system. AFFIRMED.