Tyler Uhrich v. Jim Salmonsen, et al.

• Court: District Court, D. Montana
• Decided: April 14, 2026
• Docket: 6:25-cv-00016
• Status: Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA HELENA DIVISION

TYLER UHRICH, CV 25–16–H–BMM

Plaintiff,

vs. ORDER

JIM SALMONSEN, ET AL.,

Defendants.

Two motions are pending before the Court: Defendants’ Motion to Stay or Dismiss, and Plaintiff Tyler Uhrich’s Motion for Discovery. (Docs. 37 and 38.) This matter is stayed. Uhrich’s motion is denied. I. MOTION TO STAY OR DISMISS Defendants move to stay or dismiss this case pursuant to Younger v. Harris, 401 U.S. 37 (1971). Defendants assert that adjudication of Uhrich’s claims here would impact ongoing state court criminal proceedings. (Doc. 37 at 1.) Uhrich has not responded to this motion. Uhrich’s Amended Complaint generally alleges that Defendants violated his Eighth Amendment rights by using excessive force against him on April 9, 2024. (Doc. 13 at 4 – 5.) Uhrich seeks only money damages as relief. (Doc. 13 at 5.) What happened on April 9, 2024, also serves as the basis of an ongoing criminal prosecution of Uhrich in the Third Judicial District Court, Powell County, Montana. (Doc. 37-1.) Trial in that case is currently scheduled for June 1, 2026,

according to the online calendar for the Powell County District Court. (At the time of filing Defendants’ motion, the trial was scheduled for March 30, 2026. (Doc. 37 at 3.)) As a result, Defendants contend this Court should stay or dismiss its

proceedings pursuant to Younger. “Abstention in civil cases ‘is appropriate only when the state proceedings: (1) are ongoing, (2) are quasi-criminal enforcement actions or involve a state’s interest in enforcing the orders and judgments of its courts, (3) implicate an

important state interest, and (4) allow litigants to raise federal challenges.’” Cook v. Harding, 879 F.3d 1035, 1039 (9th Cir. 2018) (quoting ReadyLink Healthcare, Inc. v. State Comp. Ins. Fund, 754 F.3d 754, 759 (9th Cir. 2014), Sprint

Commc’ns., Inc. v. Jacobs, 571 U.S. 69, 81 (2013)). If these “threshold elements” are met, then the Court must “consider whether the federal action would have the practical effect of enjoining the state proceedings and whether an exception to Younger applies.” ReadyLink, 754 F.3d at 759 (citation omitted).

The “threshold elements” of Younger are present. First, Uhrich’s allegations all relate to a specific incident that gave rise to ongoing criminal proceedings against him. State criminal enforcement actions implicate an important state

interest to enforce the local and state laws. See Younger, 401 U.S. at 43-44. Montana has a significant state interest in enforcing the criminal laws of Montana. The Court may not interfere with those interests when the process is ongoing.

Second, Uhrich will have an adequate opportunity in the Montana state district court to raise any issues he has regarding his federal rights. “[T]he threat to the plaintiff’s federally protected rights must be one that cannot be eliminated by

his defense against a single criminal prosecution.” Younger, 401 U.S. at 46. “The Supreme Court has been clear that Younger abstention is motivated by the need to refrain from granting injunctive relief where a litigant has adequate legal remedies and therefore does not face immediate irreparable injury, and by the even more

vital consideration of comity.” Duke v. Gastelo, 64 F.4th 1088, 1095 (9th Cir. 2023) (internal citation omitted). Uhrich will have the opportunity to raise his federal rights against excessive force in that is an aspect of his defense to the

charges related to the physical altercation occurring at the Montana State Prison. Uhrich also will have the state appeals process to vindicate his rights regarding his prosecution. Uhrich has opportunities within his ongoing criminal proceedings in the Montana state courts to address any alleged violations of his federal rights.

“Younger abstention is proper only when the federal relief sought would interfere in some manner in the state court litigation.” Meredith v. Oregon, 321 F.3d 807, 816–17 (9th Cir. 2003). Here, a determination regarding Uhrich’s claims

would have the effect of interfering with the “state courts’ ability to enforce constitutional principles and put the federal court in the position of making a premature ruling on a matter of constitutional law.” Gilbertson v. Albright, 381

F.3d 965, 984 (9th Cir. 2004). If this Court found that officers had used excessive force, that conclusion would likely predetermine issues in Uhrich’s state criminal trial.

If all four prongs of the Younger test are satisfied, then the Court must abstain from adjudicating Uhrich’s claims. Absent exceptional circumstances, district courts do not have discretion to avoid the doctrine if the elements of Younger abstention exist in a particular case. If abstention is appropriate under

Younger and the federal plaintiff seeks monetary damages, as Uhrich does here, the proper procedural remedy is to stay the federal proceedings pending the outcome of the ongoing state proceedings. Gilbertson, 381 F.3d at 968. This matter is

stayed, pending the outcome of Uhrich’s criminal trial. II. MOTION FOR DISCOVERY Uhrich has renewed his motion for discovery, because Defendants have not responded to his previous requests. (Doc. 38.) Uhrich’s motion includes specific

items that he claims to have sought and not received, including an incident report, a copy of the investigation into staff conduct, and video and audio. Id. Defendants oppose the motion. (Doc. 39.) Defendants claim to have

provided all of the requested items to Plaintiff Uhrich, after the date of Plaintiff’s filing. (Doc. 39 at 3.) Given the stay in this matter, the motion will be denied, subject to renewal in the future if Defendants’ disclosures remain incomplete. Based upon the foregoing, IT IS ORDERED that: l. Uhrich’s motion (Doc. 38) is DENIED, subject to renewal. 2. Defendants’ motion (Doc. 37) is GRANTED. This matter is STAYED. The Clerk of Court is directed to administratively close the case. The parties are directed to notify the Court within 30 days of the completion of state proceedings, including any direct appeals. 3. At all times, Uhrich must immediately advise the Court and opposing counsel of any change of address. Failure to do so may result in dismissal. DATED this 14th day of April, 2026.

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United States District Court