McKinnon v. Department of Corrections

CourtDistrict Court, W.D. Washington
DecidedMay 11, 2021
Docket3:21-cv-05097
StatusUnknown

This text of McKinnon v. Department of Corrections (McKinnon v. Department of Corrections) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McKinnon v. Department of Corrections, (W.D. Wash. 2021).

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT TACOMA 7 8 ARTHUR McKINNON, 9 Plaintiff, Case No. C21-5097-BHS-MLP 10 v. ORDER DENYING DEFENDANT DOC’S MOTION TO STAY 11 WASHINGTON DEPARTMENT OF CORRECTIONS, et al., 12 Defendants. 13

14 Plaintiff Arthur McKinnon is a state prisoner who is currently confined at the Stafford 15 Creek Corrections Center (“SCCC”) in Aberdeen, Washington. Plaintiff initiated this civil rights 16 action in Thurston County Superior Court in December 2020 alleging violations of state and 17 federal law relating to restrictions imposed by the Washington Department of Corrections and its 18 employees on Plaintiff’s visitation and communications with his wife and minor child. (See Dkt. 19 # 1-3.) Specifically, Plaintiff alleges that Defendants violated his federal constitutional rights 20 when they denied his wife’s application seeking permission for him to visit with his son, when 21 they improperly rejected and/or confiscated photos and correspondence relating to his wife and 22 son, and when they retaliated against him and his family for challenging the restrictions 23 regarding visitation and communications. (Id. at 10-12.) Plaintiff also alleges state law claims for 1 discrimination and for negligent infliction of emotional distress. (Id. at 10-13.) Plaintiff identifies 2 as Defendants in his complaint the Washington Department of Corrections (“DOC”), various 3 SCCC and DOC employees, and a contract mental health counselor.1 Plaintiff requests 4 declaratory and injunctive relief, and damages. (Id. at 13-14.)

5 Defendant DOC removed the case to this Court in February 2021. (Dkt. # 1.) Defendant 6 asserts in its notice of removal that this Court has original jurisdiction of this civil action under 7 28 U.S.C. § 1331, and that removal was appropriate under 28 U.S.C. § 1441 because Plaintiff 8 alleges in his complaint violations of his federal constitutional rights and specifically references 9 42 U.S.C. § 1983. (Id.) 10 On March 11, 2021, Defendant DOC filed a motion to stay this proceeding, and all 11 discovery, pursuant to the Younger abstention doctrine. (Dkt. # 7.) Defendant DOC argues 12 therein that a stay pursuant to the Younger abstention doctrine is appropriate here because 13 Plaintiff filed a personal restraint petition in the Washington appellate courts in August 2020 14 asserting claims similar to those asserted in this action and the petition remains pending at this

15 time. (See id. at 4-6.) Defendant further argues that even if the Court determines Younger does 16 not apply, it should still stay this proceeding as a matter of discretion. (Id. at 11.) Plaintiff has not 17 opposed Defendant DOC’s motion to stay. 18 The general rule concerning federal jurisdiction is that federal courts are bound to 19 adjudicate cases within their jurisdiction. New Orleans Pub. Serv., Inc. v. Council of City of New 20 Orleans, 491 U.S. 350, 358-59 (1989) (“NOPSI”) (abrogated in part on other grounds by 21 Quackenbush v. Allstate Ins. Co., 517 U.S. 706, 711 (1996)). The abstention doctrines are 22

23 1 At this point, only the DOC has been served. (Dkt. # 1 at 2.) Plaintiff has filed a motion requesting that the Court serve the remaining Defendants. (Dkt. # 6.) The Court addresses that motion in a separate Order. 1 “extraordinary and narrow exception[s]” to the rule that federal courts must exercise the 2 jurisdiction that has been conferred. Colorado River Water Conservation Dist. v. United States, 3 424 U.S. 800, 813 (1976) (citation omitted). The Supreme Court has cautioned that “[a]bstention 4 is not in order simply because a pending state court proceeding involves the same subject

5 matter.” Sprint Communications, Inc. v. Jacobs, 571 U.S. 69, 72 (2013) (citing NOPSI, 491 U.S. 6 at 373). 7 The Younger abstention doctrine “forbid[s] federal courts [from] stay[ing] or enjoin[ing] 8 pending state court proceedings.” Younger v. Harris, 401 U.S. 37, 41 (1971). “In civil cases . . . 9 Younger abstention is appropriate only when the state proceedings: (1) are ongoing, (2) are 10 quasi-criminal enforcement actions or involve a state’s interest in enforcing orders and 11 judgments of its courts, (3) implicate an important state interest, and (4) allow litigants to raise 12 federal challenges.” ReadyLink Healthcare, Inc. v. State Compensation Ins. Fund, 754 F.3d 754, 13 759 (9th Cir. 2014) (citing Sprint, 571 U.S. at 81-82; Gilbertson v. Albright, 381 F.3d 965, 977- 14 78 (9th Cir. 2004)). “If these ‘threshold elements’ are met, we then consider whether the federal

15 action would have the practical effect of enjoining the state proceedings and whether an 16 exception to Younger applies.” Id. (quoting Gilbertson, 381 F.3d at 978, 983-84). The abstention 17 doctrine is properly applied only when each of the elements of the doctrine’s requirements is 18 satisfied. AmerisourceBergen Corp. v. Roden, 495 F.3d 1143, 1148 (9th Cir. 2007). 19 There is no question that Plaintiff’s personal restraint petition was filed in state court 20 prior to the filing of the instant action and that the petition remains pending at this time. (See 21 Dkt. # 8, Ex. 1.) Thus, the first Younger requirement is satisfied. There is also no question that 22 Plaintiff was allowed to and did, in fact, raise federal challenges in his personal restraint petition. 23 (See id.) The fourth Younger requirement is therefore satisfied as well. However, the same 1 cannot be said of the second and third Younger requirements. Plaintiff’s ongoing personal 2 restraint proceeding does not constitute a “quasi-criminal enforcement action” nor does it 3 “involve a state’s interest in enforcing orders and judgments of its courts.” Rather, Plaintiff’s 4 personal restraint proceeding involves a challenge to the conditions of his current confinement

5 which falls outside the categories of cases to which Younger abstention applies. Thus, the second 6 Younger requirement is not satisfied. 7 The third requirement – that the state proceeding implicate an important state interest – is 8 likewise not satisfied here. The third requirement is satisfied when “the State’s interests in the 9 [ongoing] proceeding are so important that exercise of the federal judicial power would disregard 10 the comity between the States and the National Government.” Pennzoil Co. v. Texaco, Inc., 481 11 U.S. 1, 11 (1987). “The importance of the [state’s] interest is measured considering its 12 significance broadly, rather than by focusing on the state’s interest in the resolution of an 13 individual case.” AmerisourceBergen, 495 F.3d at 1150 (citing Baffert v. Cal. Horse Racing Bd., 14 332 F.3d 613, 618 (9th Cir. 2003); Champion Int’l Corp. v. Brown, 731 F.2d 1406, 1408 (9th

15 Cir. 1984) (“[A] challenge[ ] [to] only one . . .

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Related

Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Quackenbush v. Allstate Insurance
517 U.S. 706 (Supreme Court, 1996)
AmerisourceBergen Corp. v. Roden
495 F.3d 1143 (Ninth Circuit, 2007)
Sprint Commc'ns, Inc. v. Jacobs
134 S. Ct. 584 (Supreme Court, 2013)
Gilbertson v. Albright
381 F.3d 965 (Ninth Circuit, 2004)

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Bluebook (online)
McKinnon v. Department of Corrections, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mckinnon-v-department-of-corrections-wawd-2021.