Knight v. Ahlin

The Younger doctrine, of preventing a court from interfering with a state proceeding, does not apply where the proceedings have been postponed pending a decision by the federal court, since it does not constitute an "ongoing proceeding."

Bobby Joe Knight was convicted of rape and served twenty years in California state prison, upon his anticipated release the state filed a civil petition to have him committed under California’s Sexually Violent Predator Act (“SVPA”). Knight’s hearing for the SVPA petition had been postponed continuously for at least five years. Knight filed a pro se habeas corpus petition in state court but it was dismissed. He then filed another pro se habeas corpus petition in federal court. The district court concluded the doctrine of Younger v. Harris prevented the federal court from interfering with an ongoing state proceeding, and thus dismissed his petition. The Younger doctrine applies “when: (1) the underlying hearings at issue constitute an ongoing state judicial proceeding….” The Ninth Circuit held that Younger did not apply since it was not an “ongoing proceeding” because Knight’s SVPA hearing had been postponed pending a decision in the federal court. At oral arguments, counsel for the state indicated that a hearing on the commitment petition could be completed within 90 days; the court instructed that the state do so, or release Knight. REVERSED AND REMANDED with instructions.