June 29, 2026·8:26-cv-00451-MRA-·Unpublished·By Aisha Johnson
The Ninth Circuit affirmed a district court order denying a preliminary injunction sought by a plaintiff in a Section nineteen eighty-three action. The appellate court held that the Younger abstention doctrine required the lower court to refrain from interfering with pending state criminal proceedings.
David Allen Benson filed a pro se action under Section nineteen eighty-three seeking to enjoin state criminal proceedings against him. He appealed the district court’s order denying his motion for a preliminary injunction.
The court’s reasoning
The panel reviewed the case de novo and affirmed the district court’s decision. The court held that under the Younger abstention doctrine, the district court was required to abstain from interfering with Benson’s pending state court criminal proceedings. The court found that Benson failed to show that an exception to Younger abstention applied. The panel also rejected Benson’s contentions of judicial bias, noting that judicial rulings alone rarely support an allegation of bias.
What it means going forward
Federal courts must generally abstain from issuing injunctions that interfere with ongoing state criminal prosecutions unless a specific exception to the Younger doctrine is met.
