Seattle Pacific University v. Robert Ferguson, 104 F.4th 50

Seattle Pacific University (SPU), a private Christian university, prohibits employees from engaging in same-sex relationships or marriages, consistent with its religious doctrine.
The Washington Attorney General launched an investigation into SPU, citing complaints about its employment practices as potentially violating the Washington Law Against Discrimination (WLAD), which prohibits employment discrimination based on sexual orientation.
SPU filed suit in federal court seeking to prevent the Attorney General's investigation and any future enforcement of the WLAD against it, claiming First Amendment violations.
The WLAD exempts religious nonprofits from its employer definition, but a 2021 Washington Supreme Court decision narrowed that exemption, limiting it to the federal ministerial exception.
The district court dismissed SPU's complaint, finding a lack of redressable injury and applying Younger abstention (which discourages federal intervention in ongoing state proceedings).
On appeal, the Ninth Circuit reviewed whether SPU had standing, whether its claims were redressable, and whether abstention doctrines applied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing for retrospective claims	Probe/investigation itself chills SPU's religious rights	Request is non-binding; no concrete injury	No injury in fact for past investigation; dismissed
Standing for pre-enforcement claims	Threat of enforcement chills religious practices	WLAD may not cover ministerial employees; no imminent risk	Credible threat present; standing established
Redressability	Relief would stop unconstitutional investigation	Courts can't change state law or grant inappropriate relief	Courts can grant declaratory/injunctive relief
Younger abstention	No ongoing state proceedings	Investigation is extension of pending state action	No grounds for Younger; no ongoing proceeding

Susan B. Anthony List v. Driehaus, 573 U.S. 149 (2014) (sets pre-enforcement standing factors: intent, arguably proscribed conduct, credible threat)
Hosanna-Tabor Evangelical Lutheran Church & Sch. v. EEOC, 565 U.S. 171 (2012) (ministerial exception under the First Amendment)
Our Lady of Guadalupe Sch. v. Morrissey-Berru, 140 S. Ct. 2049 (2020) (scope of the ministerial exception)
Younger v. Harris, 401 U.S. 37 (1971) (abstention doctrine for ongoing state proceedings)
Steffel v. Thompson, 415 U.S. 452 (1974) (federal relief available when prosecution merely threatened, not pending)
MedImmune, Inc. v. Genentech, Inc., 549 U.S. 118 (2007) (declaratory judgment and standing for pre-enforcement challenges)