Benson v. Stackhouse

• Court: District Court, S.D. California
• Decided: August 28, 2025
• Docket: 3:24-cv-02428
• Status: Unknown

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 EDWARD HUNTER BENSON, ) Case No.: 24-CV-02428-BEN-DDL ) 12 Plaintiff, ) ORDER DISMISSING WITHOUT 13 v. ) PREJUDICE ) 14 JUDGE RENEE STACKHOUSE; ) COUNY OF SAN DIEGO, 15 ) Defendant. ) 16 17 I. INTRODUCTION 18 This case arises from an ongoing action in the Superior Court of California, 19 County of San Diego, involving Superior Court Family Law Judge Renee Stackhouse and 20 the County of San Diego. Plaintiff alleges violations of his constitutional and statutory 21 rights during family court proceedings. Plaintiff seeks monetary damages, injunctive 22 relief, and attorney’s fees because of his perceived unfairness in the outcome of the 23 underlying case and the anguish this has caused him.1 This case is like other cases 24 Plaintiff has brought relating to the same factual circumstances, Benson v. Torres et al, 25 3:24-cv-02424-BEN-DDL, and Benson v. Powazek et al, 3:24-cv-02436-BEN-DDL.2 26 27 1 Benson v. Benson, Case No. 23FL001293N. 2 Plaintiff’s claims for money damages are frivolous or fanciful and implausible. 28 1 II. LEGAL STANDARD 2 Younger abstention is grounded in a “longstanding public policy against federal 3 interference with state court proceedings.” Younger v. Harris, 401 U.S. 37, 43 (1971). 4 Under Younger, federal courts “[preserve] respect for state functions” such that the 5 national government protects federal rights and interests in a way that will not “unduly 6 interfere with the legitimate activities of the state[].’” Id. at 44. Pursuant to Younger, a 7 federal court may, and usually should, abstain from hearing a case in which a state civil 8 action is proceeding and where the federal action implicates a state’s interest in enforcing 9 the orders and judgments of its courts. Herrera v. City of Palmdale, 918 F.3d 1037, 1043 10 (9th Cir. 2019) (citing ReadyLink Healthcare, Inc. v. State Comp Ins. Fund, Hoye v. City 11 of Oakland, 653 F.3d 835, 843 n.5 (9th Cir. 2011) (citation omitted). 12 A “five-prong test” is used to determine “whether a civil case Younger-eligible.” 13 Seattle Pac. Univ. v. Ferguson, 104 F. 4th 50, 63 (9th Cir. 2024). Younger abstention is 14 appropriate when the state proceedings: (1) are ongoing; (2) are quasi-criminal 15 enforcement actions or involve a state’s interest in enforcing the orders and judgments of 16 its courts; (3) implicate an implicate an important state interest; (4) allow litigants to raise 17 federal constitutional challenges; and (5) when the federal action would have the practical 18 effect of enjoining the state proceedings. Yelp Inc. v. Paxton, 137 F. 4th 944, 951 (9th 19 Cir. 2025) (quoting ReadyLink Healthcare, 754 F.3d at 759).3 20 III. DISCUSSION 21 The Complaint asserts constitutional civil rights claims for compensatory damages, 22 punitive damages, injunctive relief, and attorneys’ fees under 42 U.S.C. § 1983. (ECF. 23 No. 1 at 21). 24 Plaintiff’s claims fall squarely within the bounds of the Younger abstention 25 26 27 3 There are exceptions for a “showing of bad faith, harassment, or any other unusual circumstance that would call for equitable relief,” and the exceptions are narrow. Yelp, Inc., 137 F.4th at 951 (quoting 28 | doctrine. They are subject to the doctrine for the following reasons: (1) the divorce case 2 is ongoing in state court;* (2) the Plaintiff is seeking injunctive relief from a federal court 3 that would interfere with the enforcement of a state court order; (3) divorce and family 4 proceedings are considered important state interests; and (4) the state trial and 5 appellate courts provide an adequate forum to hear constitutional claims. 6 As to the fifth prong, the fifth prong is met when the requested relief seeks to 7 enjoin or has the practical effect of enjoining the ongoing state judicial proceedings. Yelp 8 Inc., 137 F.4th at 951. This federal action would have a practical effect of enjoining the ? underlying state court proceeding because if injunctive relief were obtained, it would 10 || undermine the ongoing divorce and child custody case. Indeed, that is precisely the 11 | effect the Plaintiff intends to achieve. Thus, the fifth prong is also easily met. Lastly, 12 none of the Younger exceptions apply here. 13 Therefore, this Court abstains from exercising jurisdiction over this case. Moore v. 14 Sims, 442 U.S. 415, 435 (1979) (district court should have abstained and dismissed where 15 |! state court family relations case was proceeding); Gilbertson v. Albright, 381 F.3d 965, 16 (9th Cir. 2004) (en banc) (Younger principles counsel federal court abstention). 17 IV. CONCLUSION 18 The Complaint is hereby DISMISSED without prejudice. All pending motions are 19 || DENIED. 20 IT IS SO ORDERED. lyin, 21 || DATED: August 27, 2025 22 HON. ROGER T. BENITEZ 74 United States District Judge 24 25 |} 27 The date for determining whether Younger applies is the date the federal action is filed.” Matrai v. 28 Hiramoto, No. 21-15084, 2021 U.S. App. LEXIS 33610, 2021 WL 5276021, at *2 (9th Cir. 2021) (quoting ReadyLink, 754 F.3d at 759 (quoting Gilberson, 381 F.3d at 969 n. 4 (en banc)) (cleaned up). 3.