Gyorgy Matrai v. Joni Hiramoto
21-15084
| 9th Cir. | Nov 12, 2021Background
- Gyorgy Matrai was ordered by state family court Judge Joni T. Hiramoto to post a $5,000,000 child-abduction-prevention bond before visiting his minor son; the order remains in effect.
- Matrai did not appear at the bond hearing, had fired his attorney the day before, and his wife testified under oath that he had access to roughly $10,000,000 and bought their home for cash.
- Matrai sued in federal court under 42 U.S.C. § 1983 seeking injunctive relief (challenging the bond as violating his substantive due process right to familial association) and sued the child’s mother under the Hague Convention/ICARA for an alleged access-rights violation.
- The district court dismissed his § 1983 injunctive claim based on Younger abstention and found the Hague/ICARA access claim unripe; it dismissed the case with prejudice.
- The Ninth Circuit affirmed dismissal on Younger and ripeness grounds but held that dismissal with prejudice was an abuse of discretion and remanded with instructions to dismiss without prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Younger abstention bars Matrai’s § 1983 injunction challenging the bond | Matrai: bond violates fundamental due-process right to maintain relationship with son and federal court should enjoin enforcement | Judge/State: order enforces state court judgments/process; state has strong interest preventing abduction; federal court should abstain | Younger applies: federal court must abstain and dismiss the injunctive § 1983 claim (younger elements met) |
| Whether a bad-faith/irreparable-harm exception to Younger applies | Matrai: danger of immediate irreparable loss warrants exception | Judge/State: no evidence of bad faith or harassment in state proceedings; bond based on sworn testimony | Exception not shown; no bad faith or harassment alleged or found |
| Whether Matrai’s Hague/ICARA access claim is ripe | Matrai: Hague/UK law creates access rights violated by bond/order | Judge/State: child’s habitual residence is U.S.; Matrai did not await state-court resolution of his motion to set aside | Claim not ripe because state proceedings unresolved and Matrai filed federal suit before exhausting/awaiting state relief |
| Whether dismissal with prejudice was proper | Matrai: sought relief but relief precluded by abstention/ripeness; might seek again | Judge/State: district court dismissed the action (with prejudice) | Dismissal appropriate on grounds but with prejudice was abuse of discretion; remand to enter dismissal without prejudice |
Key Cases Cited
- Younger v. Harris, 401 U.S. 37 (1971) (abstention from federal interference in certain state proceedings)
- Juidice v. Vail, 430 U.S. 327 (1977) (state interest in enforcing court orders and contempt/power to enforce judgments)
- Pennzoil Co. v. Texaco, Inc., 481 U.S. 1 (1987) (federal injunctions may improperly interfere with state execution of judgments)
- ReadyLink Healthcare, Inc. v. State Comp. Ins. Fund, 754 F.3d 754 (9th Cir. 2014) (elements for Younger abstention)
- Gilbertson v. Albright, 381 F.3d 965 (9th Cir. 2004) (procedures when Younger applies to claims for injunctive relief)
- Huffman v. Pursue, Ltd., 420 U.S. 592 (1975) (bad-faith/harassment exception to Younger)
- Palmore v. Sidoti, 466 U.S. 429 (1984) (state duty to protect minor children in custody proceedings)
- Monasky v. Taglieri, 140 S. Ct. 719 (2020) (habitual residence governs Hague Convention claims)
- Eminence Capital, LLC v. Aspeon, Inc., 316 F.3d 1048 (9th Cir. 2003) (abuse-of-discretion standard for dismissal with prejudice)
- Canatella v. California, 404 F.3d 1106 (9th Cir. 2005) (dismissal for lack of jurisdiction is not adjudication on merits)