Abbruzzese v. Stephen F. Austin State University, 9:25-cv-00018

Plaintiff Isabella Rae Abbruzzese sued Stephen F. Austin State University (SFA) and UT Systems, alleging violations of her state and federal rights related to mold exposure, mishandling of her Title IX complaint, and retaliatory, deficient student conduct hearings.
Abbruzzese sought various forms of injunctive relief, including stays and accommodations (e.g., court-ordered mental competency test, draft coach/advocate as a reasonable accommodation).
The Magistrate Judge recommended dismissing or staying most claims under the Younger abstention doctrine and advised parties to notify the court when the underlying university proceedings concluded.
Plaintiff filed objections to the Magistrate Judge’s report, arguing errors in characterizing the university's disciplinary processes and asserting bad faith by the university.
The District Court conducted a de novo review, considering both the record and the Magistrate’s findings and recommendations.
The court ultimately overruled all of Abbruzzese’s objections and adopted the Magistrate Judge’s report in full, dismissing certain claims and staying the case pending completion of university proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Nature of student conduct hearings under Younger doctrine	Hearings lacked due process and evidentiary standards	Hearings provide required procedural safeguards	Hearings are akin to civil enforcement proceedings
Adequacy of opportunity to raise federal claims	Denied accommodations and delays prevented full opportunity	Plaintiff could and did raise claims in hearings	Hearings provide an adequate forum
Applicability of bad faith exception to Younger	Charges were retaliatory and unsubstantiated	No pattern of bad faith or harassment present	Bad faith exception does not apply
Dismissal or stay of federal action	Federal court should intervene to prevent harm	Parallel proceedings warrant abstention	Injunctive relief dismissed, case stayed

Goss v. Lopez, 419 U.S. 565 (student disciplinary due process requirements)
New Orleans Pub. Serv., Inc. v. Council of City of New Orleans, 491 U.S. 350 (definition of quasi-criminal proceedings under Younger)
Middlesex Cnty. Ethics Comm. v. Garden State Bar Ass’n, 457 U.S. 423 (criteria for Younger abstention)
Moore v. Sims, 442 U.S. 415 (abstention applies unless constitutional claims are clearly barred)
Withrow v. Larkin, 421 U.S. 35 (presumption of fairness for state administrative decisionmakers)