Ocean S. v. County of Los Angeles

CourtCourt of Appeals for the Ninth Circuit
DecidedMay 15, 2026
Docket25-1354
StatusUnpublished

This text of Ocean S. v. County of Los Angeles (Ocean S. v. County of Los Angeles) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ocean S. v. County of Los Angeles, (9th Cir. 2026).

Opinion

NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS MAY 15 2026 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT

OCEAN S.; JACKSON K.; ROSIE S.; No. 25-1354 ERYKAH B.; JUNIOR R.; ONYX G.; D.C. No. MONAIE T., individually and on behalf of 2:23-cv-06921-JAK-E all others similarly situated, MEMORANDUM* Plaintiffs - Appellees,

v.

COUNTY OF LOS ANGELES; LOS ANGELES COUNTY DEPARTMENT OF CHILDREN AND FAMILY SERVICES; LOS ANGELES DEPARTMENT OF MENTAL HEALTH,

Defendants - Appellants,

and

CALIFORNIA DEPARTMENT OF HEALTH CARE SERVICES, Doctor MARK GHALY, Secretary of the California Health and Human Services Agency, CALIFORNIA DEPARTMENT OF SOCIAL SERVICES, KIM JOHNSON, Director of the California Department of Social Services, MICHELLE BAASS, CALIFORNIA HEALTH AND HUMAN SERVICES AGENCY, CDSS Director

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. JENNIFER TROIA,

Defendants.

Appeal from the United States District Court for the Central District of California John A. Kronstadt, District Judge, Presiding

Argued and Submitted September 19, 2025 Pasadena, California

Before: CLIFTON, BYBEE, and LEE, Circuit Judges.

Plaintiffs in this case are a putative class of foster youth in Los Angeles

County between the ages of 16 and 21, also referred to as “transition age foster

youth.” They allege that the County’s foster care system has denied them

“meaningful access to [] crucial housing, mental health, and other services to

which they are legally entitled.” Among other things, Plaintiffs argue that there are

too few foster placements, that the placements are arbitrary, and that certain health

services are unavailable, all in violation of the Constitution and various federal

laws.

Defendants appeal from the district court’s order denying their motion to

dismiss for lack of subject matter jurisdiction. Defendants argue that Plaintiffs’

lawsuit presents questions from which federal courts ought to abstain under

Younger v. Harris, 401 U.S. 37 (1971). Defendants also argue that Plaintiffs lack

standing under Article III of the Constitution because their alleged injuries are not

2 25-1354 redressable.

A district court’s decisions on standing and Younger abstention are reviewed

de novo. See Colwell v. Dep’t of Health & Hum. Servs., 558 F.3d 1112, 1121 (9th

Cir. 2009). Although denial of a motion to dismiss is a non-final order generally

not subject to appeal, a permissive interlocutory appeal is allowed when a non-final

order “involves a controlling question of law as to which there is substantial

ground for difference of opinion” and when “an immediate appeal from the order

may materially advance the ultimate termination of the litigation.” 28 U.S.C.

§ 1292(b). That is the case here. The district court certified its denial of

Defendants’ motion to dismiss for immediate appeal, and this court granted

permission to appeal. Accordingly, we have jurisdiction, and we affirm in part and

dismiss in part.

1. Younger abstention is not warranted in this case. Federal courts have a

“virtually unflagging obligation . . . to exercise the jurisdiction given them.” Colo.

River Water Conservation Dist. v. United States, 424 U.S. 800, 817 (1976). As

such, “[a]bstention from the exercise of federal jurisdiction is the exception, not

the rule.” Id. at 813. That includes Younger abstention, which the Supreme Court

has clarified applies only to three types of cases: (1) “ongoing state criminal

prosecutions”; (2) “certain civil enforcement proceedings”; and (3) “civil

proceedings involving certain orders uniquely in furtherance of the state courts’

3 25-1354 ability to perform their judicial functions.” Sprint Commc’ns., Inc. v. Jacobs, 571

U.S. 69, 78 (2013) (citation modified). Relevant to the instant case is the second

category, which “generally concern[s] state proceedings akin to a criminal

prosecution.” Id. at 79 (citation modified). The Court has further clarified that

civil enforcement proceedings akin to a criminal prosecution typically involve

state-initiated investigations that culminate in formal charges intended to sanction

a plaintiff. See id. at 79–80.

California’s dependency proceedings do not fall under this second category

of cases. That is because an initial custody action, which is akin to a criminal

prosecution, is conceptually distinct from the subsequent and ongoing dependency

proceedings at issue here. Cf. Moore v. Sims, 442 U.S. 415, 423 (1979) (applying

Younger abstention in the “temporary removal of a child in a child-abuse

context”); Sprint, 571 U.S. at 79 (describing the underlying action in Moore as a

“state-initiated proceeding to gain custody of children” (emphasis added)). On a

previous occasion, this court has similarly treated an initial custody hearing as

being conceptually distinct from subsequent proceedings. See L.H. v. Jamieson,

643 F.2d 1351, 1354 (9th Cir. 1981) (per curiam) (“[Plaintiffs’] cause of action

arises after a court has committed a juvenile to the state’s custody.” (emphasis

added)); cf. Arevalo v. Hennessy, 882 F.3d 763, 766 (9th Cir. 2018) (holding that

Younger abstention on a bail hearing is inappropriate, as it is distinct from the

4 25-1354 criminal prosecution).

Further, as the Supreme Court of California has recognized, dependency

proceedings are “designed not to prosecute a parent, but to protect the child.” In re

Josiah Z., 115 P.3d 1133, 1137 (Cal. 2005) (internal quotation marks omitted), as

modified (Aug. 10, 2005). It has further concluded that “once reunification

services [are] terminated,” the juvenile court’s efforts shift from being “on a

parent’s challenge to a custody order” to being about “the child’s placement and

well-being.” In re Marilyn H., 851 P.2d 826, 833 (Cal. 1993). For these reasons,

we conclude that the ongoing dependency proceedings at issue here, unlike

custody hearings, do not fit into the exceptional category of civil enforcement

proceedings akin to a criminal prosecution that warrants Younger abstention. The

district court’s refusal to abstain under Younger is affirmed. We express no view

regarding the applicability of other abstention doctrines, which the parties may

raise in the future.

2. Reviewing the district court’s ruling on standing would require us to

consider allegations in a complaint that has since been superseded by a subsequent

second amended complaint.1 That subsequent complaint was filed after the district

1 Falck’s conclusion that an amended complaint renders the prior complaint “a legal nullity” because the court may “no longer grant any effective relief,” Falck N. Cal. Corp. v.

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Related

Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Moore v. Sims
442 U.S. 415 (Supreme Court, 1979)
In Re Marilyn H
851 P.2d 826 (California Supreme Court, 1993)
Colwell v. Department of Health and Human Services
558 F.3d 1112 (Ninth Circuit, 2009)
In Re Josiah Z.
115 P.3d 1133 (California Supreme Court, 2005)
Erick Arevalo v. Vicki Hennessy
882 F.3d 763 (Ninth Circuit, 2018)
Sprint Commc'ns, Inc. v. Jacobs
134 S. Ct. 584 (Supreme Court, 2013)
L. H. v. Jamieson
643 F.2d 1351 (Ninth Circuit, 1981)

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