Frederick Karash v. Erie County Municipality, 670 F. App'x 41

Pro se plaintiff Frederick Karash sued under 42 U.S.C. § 1983, challenging state speeding charges and seeking to enjoin the ongoing state prosecution; defendants included Erie County, state court judges, and district attorneys.
Karash alleged prosecutors brought "trumped up" charges and judges made improper rulings resulting in his conviction; he sought federal relief while state appeals remained pending.
Defendants moved to dismiss under Fed. R. Civ. P. 12(b)(6); the Magistrate Judge (by consent) granted dismissal.
The District Court held the suit barred by Younger abstention, found many defendants immune, and concluded the claims otherwise failed to state relief.
Karash appealed; defendants moved in this Court to summarily affirm and the panel reviewed the dismissal de novo.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether federal court must abstain under Younger when state criminal proceedings are pending	Karash argued federal relief was warranted to enjoin prosecutorial and judicial misconduct	Defendants argued Younger requires abstention because state proceedings are ongoing, implicate important state interests, and permit federal claims to be raised in state court	Court held Younger applies and abstention is required
Whether exceptions to Younger (bad faith, harassment, frivolous prosecution) apply	Karash contended prosecutorial harassment and bad-faith prosecution (threat to increase charges) justified federal intervention	Defendants argued threats and alleged vindictiveness do not meet narrow exceptions and prosecution was not frivolous	Court held Karash failed to show harassment, bad faith, or extraordinary circumstances to overcome Younger
Whether defendants are entitled to immunity	Karash sought damages and injunctive relief against prosecutors and judges	Defendants argued prosecutorial and judicial immunity bar claims	Court agreed many defendants were immune (affirming District Court)
Whether the complaint otherwise stated a claim under § 1983	Karash asserted constitutional violations arising from plea/coercion and judicial rulings	Defendants argued the complaint failed to plead actionable federal claims and relief was available in state appellate process	Court held the claims otherwise failed to state relief in federal court

Younger v. Harris, 401 U.S. 37 (Younger abstention doctrine limits federal interference with ongoing state criminal proceedings)
Huffman v. Pursue, Ltd., 420 U.S. 592 (Younger applies during pendency of state appellate proceedings)
Perez v. Ledesma, 401 U.S. 82 (narrow exceptions to Younger for bad faith or harassment)
Sprint Commc’ns, Inc. v. Jacobs, 134 S. Ct. 584 (state proceedings implicate important state interests)
Evans v. Court of Common Pleas, 959 F.2d 1227 (prosecutorial vindictiveness generally insufficient to avoid Younger abstention)
Alabama v. Smith, 490 U.S. 794 (prosecutorial threats to increase charges upheld in certain plea contexts)
Taliaferro v. Darby Twp. Zoning Bd., 458 F.3d 181 (de novo review of dismissal order)