Richard Rynearson, III v. Robert Ferguson
903 F.3d 920
| 9th Cir. | 2018Background
- Rynearson, a frequent online commentator, posted critical content about a neighbor (Moriwaki) and created Facebook pages using Moriwaki’s name; Moriwaki obtained a temporary then permanent Washington stalking protection order prohibiting various contacts and online uses.
- The municipal court found Rynearson stalked, cyberstalked, and harassed Moriwaki; it rejected Rynearson’s First Amendment defense; the superior court later vacated the order on First Amendment grounds (Moriwaki did not appeal).
- While the municipal protection-order proceeding was pending, Rynearson filed a § 1983 federal suit seeking a declaratory judgment and injunction that Washington’s cyberstalking statute (Wash. Rev. Code § 9.61.260) is unconstitutional.
- Defendants (the Washington Attorney General and Kitsap County Prosecuting Attorney) moved to dismiss; the district court dismissed under Younger abstention.
- The Ninth Circuit reviewed de novo and analyzed Younger via its five‑prong ReadyLink test, focusing on whether protection-order proceedings are quasi‑criminal/state enforcement actions and whether the federal suit would practically enjoin the state proceedings.
- The Ninth Circuit concluded protection‑order proceedings are civil, victim‑initiated protective actions (not quasi‑criminal or state enforcement proceedings) and that a federal ruling on the cyberstalking statute would not practically enjoin the protection proceedings; it reversed and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Younger abstention bars federal review of Rynearson’s constitutional challenge to the cyberstalking statute while state protection‑order proceedings were pending | Rynearson: protection‑order proceedings are private civil matters, not the sort of quasi‑criminal or state‑enforcement actions that trigger Younger; federal court should decide the statute’s constitutionality | Defendants: ongoing protection proceedings are akin to quasi‑criminal/state enforcement and federal adjudication would interfere with state proceedings, so Younger requires abstention | Younger abstention inappropriate: protection‑order proceedings are not quasi‑criminal nor state enforcement, and federal relief would not practically enjoin the state proceedings; reverse dismissal |
| Whether Washington protection‑order proceedings involve the state’s interest in enforcing its courts’ orders and judgments (ReadyLink prong 2) | Rynearson: proceedings are initiated and pursued by private petitioners to obtain protection; state actors need not initiate or be parties | Defendants: protection orders have punitive/enforcement aspects and reference criminal statutes, making them akin to state enforcement actions | Held: proceedings are primarily private, protective (not punitive), and do not implicate the state’s core interest in enforcing judicial processes; prong 2 not met |
| Whether a federal declaration invalidating the cyberstalking statute would have the practical effect of enjoining the state protection proceedings (ReadyLink prong 5) | Rynearson: even if the statute were struck down, protection orders can rest on stalking or harassment independent of the cyberstalking statute; contempt/prosecution for violating an order would remain available | Defendants: invalidating the statute would undercut the municipal court’s application and could prevent enforcement tied to cyberstalking | Held: federal relief would not practically enjoin the protection proceedings or prevent prosecution for order violations; prong 5 not satisfied |
| Whether any Younger exceptions apply | Rynearson: no special circumstances justify abstention given the foregoing | Defendants: Younger applies, so exceptions unnecessary | Held: Younger inapplicable; no need to invoke exceptions because threshold requirements not met |
Key Cases Cited
- Younger v. Harris, 401 U.S. 37 (establishing federal-court abstention doctrine for ongoing state criminal proceedings)
- ReadyLink Healthcare, Inc. v. State Comp. Ins. Fund, 754 F.3d 754 (9th Cir.) (articulating five‑prong test for Younger abstention in civil cases)
- Sprint Communications, Inc. v. Jacobs, 571 U.S. 69 (discussing characteristics of quasi‑criminal/state enforcement actions for Younger purposes)
- Huffman v. Pursue, Ltd., 420 U.S. 592 (applying Younger to state nuisance proceedings)
- Juidice v. Vail, 430 U.S. 327 (abstention where federal suit interfered with state contempt procedures)
- Middlesex Cty. Ethics Comm. v. Garden State Bar Ass’n, 457 U.S. 423 (applying Younger to state disciplinary proceedings)
- Potrero Hills Landfill, Inc. v. County of Solano, 657 F.3d 876 (9th Cir.) (noting Younger is narrow exception and timing for analysis)
- AmerisourceBergen Corp. v. Roden, 495 F.3d 1143 (9th Cir.) (requiring strict satisfaction of Younger elements)
- Pennzoil Co. v. Texaco, Inc., 481 U.S. 1 (discussing state interests in administering judicial system processes)
- Cook v. Harding, 879 F.3d 1035 (9th Cir.) (holding statutory‑challenge did not implicate state interest in enforcing court judgments)