Angel Michael Crockford v. Clark County Department of Family Services, et al.

CourtDistrict Court, D. Nevada
DecidedNovember 21, 2025
Docket2:25-cv-00917
StatusUnknown

This text of Angel Michael Crockford v. Clark County Department of Family Services, et al. (Angel Michael Crockford v. Clark County Department of Family Services, et al.) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Angel Michael Crockford v. Clark County Department of Family Services, et al., (D. Nev. 2025).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 Case No.: 2:25-cv-00917-JAD-MDC Angel Michael Crockford, 4 Plaintiff Order Granting in Part Clark County’s 5 v. Motion to Dismiss, Granting Clark County’s Motion to Seal, Granting 6 Clark County Department of Family Services, Cuscianna’s Motion to Dismiss, Denying all et al., Other Motions as Moot, and Staying 7 Remaining Claims under Younger v. Harris Defendants 8 [ECF Nos. 25, 26, 31, 86, 101, 109]

10 Angel Michael Crockford sues the Clark County Department of Family Services, the 11 Clark County District Attorney’s Office, individual employees of both agencies, and his ex-wife 12 Alicia Renee Cuscianna for alleged transgressions that took place during state-court child- 13 custody proceedings. Clark County, on behalf of its departments and employees, moves to 14 dismiss because Crockford didn’t exhaust administrative remedies, his complaint fails to state a 15 claim, and this court should abstain from hearing this case under Younger v. Harris,1 and it 16 moves to seal some documents related to its briefing. Cuscianna also moves to dismiss, 17 contending that she is not a state actor and thus cannot be sued for constitutional violations. For 18 his part, Crockford moves for a temporary restraining order and a preliminary injunction, and he 19 objects to the magistrate judge’s order granting Clark County’s motion to stay discovery. 20 I dismiss Crockford’s § 1983 claim against Cuscianna because she is a private actor and 21 Crockford’s joint-actor theory doesn’t apply to the facts alleged in the complaint. And I decline 22 to exercise supplemental jurisdiction over Crockford’s state-law claims against his ex-wife, so I 23

1 Younger v. Harris, 401 U.S. 37 (1971). 1 dismiss those claims without prejudice to Crockford’s ability to refile them in state court. I 2 conclude that the Younger abstention doctrine bars this court’s consideration of Crockford’s 3 claims against the remaining defendants. His state-court actions remain pending, and his 4 arguments insisting that Younger doesn’t apply are unavailing. So I grant the County’s motion in 5 part and dismiss Crockford’s complaint to the extent that it seeks injunctive and declaratory

6 relief, but I stay his claims for monetary damages against the County defendants pending the 7 final outcome of all the state proceedings referenced in the complaint. I then grant Clark 8 County’s motion to seal documents related to the child-custody proceedings and I deny all 9 remaining motions as moot. Crockford is advised that this case is now STAYED, so he may not 10 file anything else in this action until his state-court cases including any appeals have concluded. 11 At that point, Crockford may file a motion to lift the stay. All other motions or filings may be 12 denied or struck without prior notice. 13 Discussion 14 A. The Younger abstention doctrine bars consideration of Crockford’s claims against 15 the County defendants.

16 The comity-based abstention doctrine developed in the Supreme Court case of Younger v. 17 Harris prevents federal courts from interfering in pending state-court proceedings even if there is 18 an allegation of a constitutional violation.2 Federal courts may only intervene if there is an 19 extraordinary circumstance that creates a threat of irreparable injury that cannot be eliminated 20 through proper motion practice in the state-court case.3 The Younger abstention doctrine 21 22

23 2 Id. at 53–54. 3 Id. 1 “reflects the strong federal policy against federal interference with state judicial proceedings,”4 2 and “minimal respect for the state processes . . . precludes any presumption that the state courts 3 will not safeguard federal constitutional rights.”5 The Ninth Circuit has articulated “a four-part 4 test to determine when Younger requires” a federal court to abstain: “Younger abstention is 5 appropriate when: (1) there is an ongoing state judicial proceeding; (2) the proceeding implicates

6 important state interests; (3) there is an adequate opportunity in the state proceedings to raise 7 constitutional challenges; and (4) the requested relief seeks to enjoin or has the practical effect of 8 enjoining the ongoing state judicial proceeding.”6 9 All four of these factors are present here. Crockford’s complaint alleges that the 10 proceedings in state court are ongoing after a negotiated settlement agreement fell through. The 11 proceedings also implicate important state interests: the Supreme Court and Ninth Circuit have 12 long held that Younger abstention is appropriately applied to challenges arising from child- 13 custody and parentage proceedings.7 And it’s clear from Crockford’s complaint and the exhibits 14 he attaches to his motion for a temporary restraining order that he has been given the opportunity

15 to raise his allegations in the state-court proceedings, even if he was dissatisfied with the state 16 court’s rulings on those issues. And if this court were to wade into the issues that Crockford 17 raises—among them, whether the state-court judge issued proper rulings and whether 18 representatives from the District Attorney’s Office suppressed evidence—granting his requested 19 relief would have the practical effect of enjoining the state court’s proceedings. 20 4 Delta Dental Plan of Cal., Inc. v. Mendoza, 139 F.3d 1289, 1294 (9th Cir. 1998). 21 5 Middlesex Cnty. Ethics Comm’n v. Garden State Bar Ass’n, 457 U.S. 423, 431 (1982). 22 6 Duke v. Gastelo, 64 F.4th 1088, 1094 (9th Cir. 2023) (quoting Arevalo v. Hennessy, 882 F.3d 763, 765 (9th Cir. 2018)). 23 7 Moore v. Sims, 442 U.S. 415, 423, 429 (1979); Juidice v. Vail, 430 U.S. 327, 336 n.12 (1977); Ankenbrandt v. Richards, 504 U.S. 689, 697–701 (1992). 1 Crockford insists that Younger abstention doesn’t apply because the state proceedings 2 were maintained in bad faith and for retaliatory purposes, they are rife with “flagrant 3 constitutional violations,” and “the state forum is inadequate to protect federal rights.”8 But 4 stripped of Crockford’s conclusory statements that the wrongs he suffered amount to 5 constitutional violations, the facts simply don’t support those conclusions. For example,

6 Crockford asserts that one of the caseworkers didn’t present exculpatory evidence to the court 7 because she didn’t find it relevant, and he contends that the caseworker’s actions violated her 8 constitutional duty not to suppress exculpatory evidence under Brady v. Maryland.9 But 9 Crockford acknowledges that he received the evidence he is complaining of; indeed, at one point 10 he confirms that he is the one who gave some of that evidence to the caseworker. So his 11 complaint doesn’t allege any suppression of exculpatory evidence in Brady because a Brady 12 violation happens only when the state fails to turn over evidence to the defendant in a criminal 13 case; Brady does not require the state to present all exculpatory evidence in open court.10 14 Crockford’s allegations of bias by the state-court judge also don’t show that the state

15 court is incapable of ruling on his constitutional concerns.

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Bluebook (online)
Angel Michael Crockford v. Clark County Department of Family Services, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/angel-michael-crockford-v-clark-county-department-of-family-services-et-nvd-2025.