Dawson v. Napa County

N.D. California

Dawson v. Napa County

DecidedMay 4, 2025

Docket3:25-cv-01923

StatusUnknown

This text of Dawson v. Napa County (Dawson v. Napa County) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Dawson v. Napa County, (N.D. Cal. 2025).

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1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 AMANDA JEANE DAWSON, Case No. 25-cv-01923-JSC

8 Plaintiff, ORDER DENYING PLAINTIFF’S 9 v. MOTION FOR A TEMPORARY RESTRAINING ORDER 10 NAPA COUNTY, et al., Re: Dkt. No. 15 Defendants. 11

12 13 On February 24, 2025, Amanda Dawson—proceeding without attorney representation— 14 sued Napa County, Napa County Superior Court, Napa Police Department, Napa County Child 15 Welfare Services, and Napa County Public Defender’s Office. (Dkt. No. 1.) On May 2, 2025, 16 Ms. Dawson filed the pending motion for a temporary restraining order. (Dkt. No. 15.) She seeks 17 “to immediately stay all state criminal proceedings, restraining orders, and juvenile dependency 18 actions related to Plaintiff while this federal civil rights case is pending.” (Id. at 1.) 19 Having carefully considered Ms. Dawson’s submissions, the Court determines oral 20 argument is not required, see N.D. Cal. Civ. L.R. 7-1(b), and DENIES Ms. Dawson’s motion for a 21 temporary restraining order. “[F]ederal courts sitting in equity cannot, absent exceptional 22 circumstances, enjoin pending state criminal proceedings.” ReadyLink Healthcare, Inc. v. State 23 Comp. Ins. Fund, 754 F.3d 754, 758 (9th Cir. 2014) (citing Younger v. Harris, 401 U.S. 37, 43-54 24 (1971)). This principle has been extended “to civil enforcement actions akin to criminal 25 proceedings, and to suits challenging the core of the administration of a State’s judicial system.” 26 Id. (cleaned up); see Moore v. Sims, 442 U.S. 415, 423 (1979) (concluding Younger abstention 27 appropriate in proceeding to gain custody of children allegedly abused by their parents). Ms. 1 state actions, nor does the Court—having reviewed Ms. Dawson’s submissions—find exceptional 2 || circumstances. 3 This Order disposes of Docket No. 15. 4 IT IS SO ORDERED. 5 Dated: May 4, 2025 6 7 ne JAQQUELINE SCOTT CORL 8 United States District Judge 9 10 11 12

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1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 AMANDA JEANE DAWSON, Case No. 25-cv-01923-JSC

8 Plaintiff, ORDER DENYING PLAINTIFF’S 9 v. MOTION FOR A TEMPORARY RESTRAINING ORDER 10 NAPA COUNTY, et al., Re: Dkt. No. 15 Defendants. 11

12 13 On February 24, 2025, Amanda Dawson—proceeding without attorney representation— 14 sued Napa County, Napa County Superior Court, Napa Police Department, Napa County Child 15 Welfare Services, and Napa County Public Defender’s Office. (Dkt. No. 1.) On May 2, 2025, 16 Ms. Dawson filed the pending motion for a temporary restraining order. (Dkt. No. 15.) She seeks 17 “to immediately stay all state criminal proceedings, restraining orders, and juvenile dependency 18 actions related to Plaintiff while this federal civil rights case is pending.” (Id. at 1.) 19 Having carefully considered Ms. Dawson’s submissions, the Court determines oral 20 argument is not required, see N.D. Cal. Civ. L.R. 7-1(b), and DENIES Ms. Dawson’s motion for a 21 temporary restraining order. “[F]ederal courts sitting in equity cannot, absent exceptional 22 circumstances, enjoin pending state criminal proceedings.” ReadyLink Healthcare, Inc. v. State 23 Comp. Ins. Fund, 754 F.3d 754, 758 (9th Cir. 2014) (citing Younger v. Harris, 401 U.S. 37, 43-54 24 (1971)). This principle has been extended “to civil enforcement actions akin to criminal 25 proceedings, and to suits challenging the core of the administration of a State’s judicial system.” 26 Id. (cleaned up); see Moore v. Sims, 442 U.S. 415, 423 (1979) (concluding Younger abstention 27 appropriate in proceeding to gain custody of children allegedly abused by their parents). Ms. 1 state actions, nor does the Court—having reviewed Ms. Dawson’s submissions—find exceptional 2 || circumstances. 3 This Order disposes of Docket No. 15. 4 IT IS SO ORDERED. 5 Dated: May 4, 2025 6 7 ne JAQQUELINE SCOTT CORL 8 United States District Judge 9 10 11 12

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