Background
Cyrus Mark Sanai, a California attorney subject to state bar disciplinary proceedings, filed a pro se action under Section forty two United States Code one nine eight three against California Supreme Court justices. He alleged the disciplinary process was constitutionally defective. The Ninth Circuit previously affirmed the dismissal of his claims based on abstention under Younger versus Harris. Sanai now appeals the district court’s denial of his motion for relief from judgment under Rule sixty B six, arguing that the Supreme Court’s decision in Williams versus Reed presented an intervening change in law.
The court’s reasoning
The panel reviewed the district court’s denial for abuse of discretion. It held that the district court did not abuse its discretion by failing to explicitly analyze all six factors from Henson versus Fidelity National Financial. Although the lower court did not name the factors, it engaged in the relevant equitable analysis. The first and fifth Henson factors supported the conclusion that nothing in the motion merited relief, making the remaining factors not salient under the circumstances.
What it means going forward
The decision maintains the dismissal of Sanai’s federal civil rights claims against the state court justices and upholds the denial of his request to vacate the prior judgment.
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