Laflam v. Hillman
2:25-cv-01039
W.D. Wash.Jul 9, 2025Background
- Adrienne LaFlam challenged a King County Superior Court order requiring her to have only professionally supervised contact with her children, which she argued was effectively a termination of custody without a finding of unfitness.
- LaFlam claimed the state order was issued without an evidentiary hearing and ignored her financial hardship and disability accommodation requests.
- She sought federal injunctive relief against the state court order, alleging procedural and constitutional violations, including discrimination and retaliation.
- The federal court dismissed her action based on Younger abstention, ruling it should not interfere with ongoing state proceedings affecting important state interests.
- LaFlam moved under Fed. R. Civ. P. 59(e) to amend the judgment, arguing improper abstention, and sought an emergency partial stay of state court proceedings.
- The district court denied both motions, maintaining that abstention applied because the state system provided an adequate opportunity to address her federal claims.
Issues
| Issue | Plaintiff’s Argument | Defendant’s Argument | Held |
|---|---|---|---|
| Applicability of Younger abstention | State forum is inadequate due to procedural barriers, bad faith, or harassment | State forum is adequate and not structurally biased | Younger abstention applies; state forum is adequate |
| Exceptions to Younger | Extraordinary circumstances (bias, bad faith, harassment) bar abstention | No such exceptional circumstances present | No exception found; abstention required |
| Whether federal suit fits Sprint categories | State custody orders don’t trigger Sprint abstention | Case challenges state process, implicating state judicial function | Fits Sprint; abstention warranted |
| Amending judgment under Rule 59(e) | Newly discovered evidence/procedural error justifies amendment | No new evidence; no manifest error or injustice | Rule 59(e) standards not met; motion denied |
Key Cases Cited
- Carroll v. Nakatani, 342 F.3d 934 (9th Cir. 2003) (Rule 59(e) is an extraordinary remedy to be used sparingly)
- Allstate Ins. Co. v. Herron, 634 F.3d 1101 (9th Cir. 2011) (Rule 59(e) relief standard)
- Baffert v. Cal. Horse Racing Bd., 332 F.3d 613 (9th Cir. 2003) (exceptions to Younger abstention)
- Gibson v. Berryhill, 411 U.S. 564 (1973) (state forum must be adequate for Younger to apply)
- Younger v. Harris, 401 U.S. 37 (1971) (Younger abstention doctrine)
- Sprint Communications, Inc. v. Jacobs, 571 U.S. 69 (2013) (categories where Younger abstention applies)
- Middlesex Cty. Ethics Comm. v. Garden State Bar Ass'n, 457 U.S. 423 (1982) (three-prong test for Younger abstention)