Steven Knox v. Kate Brown
702 F. App'x 639
| 9th Cir. | 2017Background
- Plaintiff Steven Knox, an Oregon state prisoner, appealed pro se a district court judgment dismissing his 42 U.S.C. § 1983 claims arising from denial/deferral of parole.
- Knox advanced three claims challenging parole denials and sought injunctive relief; he also pursued a state-court appeal related to the same parole decision.
- The district court dismissed Claim One and Claim Three for being Heck/Winkinson-barred because success would imply invalidity of confinement/duration and Knox had not invalidated his conviction or sentence.
- The district court dismissed Claim Two under Younger abstention because a related state-court proceeding was pending and no abstention exceptions applied.
- The district court denied Knox’s motion for reconsideration; the Ninth Circuit reviewed de novo and affirmed, declining to reach the merits or preliminary-injunction rulings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether claims seeking correction of parole deferral are cognizable under § 1983 despite potential effect on confinement duration | Knox argued his challenges were procedurally focused and would not necessarily shorten confinement | Defendants argued success would necessarily imply invalidity of confinement/duration and is barred unless conviction/sentence invalidated | Dismissed without prejudice under Heck/Wilkinson bar |
| Whether district court must abstain under Younger given ongoing state-court appeal | Knox sought federal relief despite pending state proceedings | Defendants asserted Younger requires abstention because state process was underway and no exception applied | Dismissed without prejudice under Younger abstention |
| Whether any exception to Younger applied because of alleged constitutional violations | Knox contended constitutional claims warrant federal intervention | Defendants maintained constitutional claim alone does not overcome Younger abstention | No exception applied; Younger abstention stands |
| Whether district court abused discretion denying reconsideration of dismissal | Knox asked for reconsideration of dismissal and injunction denials | Defendants argued no grounds under Rule 59(e) were shown | Denial affirmed; no abuse of discretion |
Key Cases Cited
- Wilkinson v. Dotson, 544 U.S. 74 (2005) (§ 1983 claim barred if success would necessarily imply invalidity of confinement or its duration)
- Heck v. Humphrey, 512 U.S. 477 (1994) (favorable termination rule bars § 1983 actions that would imply invalid conviction or sentence)
- Younger v. Harris, 401 U.S. 37 (1971) (federal courts must abstain to avoid interfering with ongoing state proceedings)
- ReadyLink Healthcare, Inc. v. State Comp. Ins. Fund, 754 F.3d 754 (9th Cir. 2014) (articulates Younger abstention requirements in civil cases)
- Baffert v. Cal. Horse Racing Bd., 332 F.3d 613 (9th Cir. 2003) (explains Younger exceptions and that asserted constitutional violations alone do not automatically defeat abstention)