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Media Alerts - Miles v. Wesley - Ninth Circuit
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November 28, 2015
  Miles v. Wesley - Ninth Circuit
Headline: Ninth Circuit decides district court should abstain from interfering with Los Angeles County's administration and management of its judicial system.

Area of Law: Federal Abstention, Class Action

Issue Presented: Whether the district court properly dismissed a class action suit on federal abstention grounds where plaintiffs sought federal review of a County's administration and management of its own court system.

Brief Summary: After years of budget cuts, Los Angeles ("L.A.") County abandoned its "a court in every neighborhood" model because the high operating costs of maintaining its 58 courthouses became unsustainable. The L.A. County court system set up "hub" courts across the county that heard specific legal matters, instead of all courts hearing all cases. Brenda Miles, representing the plaintiff class, challenged the new "hub" court model claiming the consolidation of all unlawful detainer cases (tenant eviction) into seven "hub" courts disproportionately impacted poor, disabled, and minority residents. The federal district dismissed the case on abstention grounds, under O'Shea v. Littleton, holding federal intervention of the County judicial system would violate the longstanding public policy against federal court interference with state court proceedings.

Extended Summary: Los Angeles County instituted its "neighborhood court" model in the late 1990s to provide easy access to courts for all L.A. residents. As of 2000, L.A. County operated 58 different courthouses, making up the largest trial court in the nation. After multiple legislative budget cuts over a number of years, the L.A. County court system initiated significant changes; by 2015, the County had shut down 20 of its 58 courthouses and consolidated all unlawful detainer (tenant eviction) cases into 7 "hub" courts.

Plaintiffs filed this class action in federal court alleging the new L.A. County "hub" court model violated numerous constitutional and statutory rights because it disproportionately impacted poor, disabled, and minority L.A. residents. But the district court dismissed the case on federal abstention grounds under O'Shea v. Littleton, 414 U.S. 488 (1974).

O'Shea v. Littleton is the controlling authority for abstention matters. The Supreme Court in O'Shea determined federal courts should generally abstain from interfering with state court matters where principles of federalism, comity, and institutional competence are implicated. The O'Shea opinion proscribes any ongoing federal audit of state criminal court proceedings; the same policy was later extended to civil suits in Rizzo v. Goode, 423 U.S. 362 (1976). Federal courts should determine whether abstention is proper on a case-by-case basis and be very reluctant to grant relief in sensitive state activities such as administrating the judicial system. Younger v. Harris, 401 U.S. 37 (1971).

The Ninth Circuit panel reviewed plaintiff's requested relief in determining whether it should abstain the matter. Plaintiffs were requesting an injunction preventing the county from shutting down even a single courthouse or adopting the "hub" court model for tenant eviction cases. The panel unanimously held that if the federal court were to stop L.A. County from making its own administrative decisions regarding its court system, it would be engaging in the exact sort of "heavy federal intervention" that O'Shea and Younger sought to prevent.

The O'Shea decision illustrates the longstanding public policy against federal court interference with the administration of state judicial systems. The Ninth Circuit confirmed the O'Shea policy by affirming the District Court's decision to dismiss the case on federal abstention grounds.

To read full opinion, please visit:

Panel: Ferdinand F. Fernandez, Barrington D. Parker, Jr., and Jacqueline H. Nguyen, Circuit Judges.

Date of Argument: March 4, 2015 - Pasadena, California

Date of Issued Opinion: September 8, 2015

Docket Number: No. 13-55620

Decided: Dismissal of the class action for federal abstention grounds under O'Shea v. Littleton is affirmed.

Case Alert Author: Brian D. Shapiro

Counsel: Richard A. Rothschild (argued), Sue L. Himmelrich, and Navneet Grewal, Western Center on Law & Poverty, Los Angeles, California; Maria Palomares, Alexander Prieto, Brian Bilford and David Pallack, Neighborhood Legal Services of Los Angeles County, Pacoima, California; Paula D. Pearlman and Michelle Uzeta, Disability Rights Legal Center, Los Angeles, California; Barbara Schultz, Paul J. Estuar, and Fernando Gaytan, Legal Aid Foundation of Los Angeles, Los Angeles, California, for Plaintiffs-Appellants.

Robert A. Naeve (argued) and Nathaniel P. Garrett, Jones Day, Irvine, California, for Defendants-Appellees the Honorable David S. Wesley and Sherri R. Carter.

Susan K. Smith, Deputy Attorney General, Office of the Attorney General, Los Angeles, California, for Defendants- Appellees State of California and Edmund G. Brown, Jr.

Author of Opinion: Judge Nguyen

Case Alert Supervisor: Professor Ryan T. Williams

    Posted By: Ryan Williams @ 11/28/2015 11:49 PM     9th Circuit  

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