Achar v. Copko

Background

Sneha Achar, proceeding without a lawyer, filed an emergency motion asking the court to stay, or temporarily halt, her ongoing state family-court proceedings. The motion sought preliminary injunctive relief, which is an extraordinary temporary court order issued before the case is finally decided.

Legal standard

The court explained that Achar had to show likely irreparable harm and either a likelihood of success on the merits or sufficiently serious legal questions that warranted litigation, together with a balance of hardships strongly favoring her. The court emphasized that preliminary injunctive relief requires a clear showing by the person requesting it.

The court also discussed the Younger abstention doctrine. Under that doctrine, federal courts generally must refrain from exercising jurisdiction when doing so would call into question ongoing state proceedings.

Ruling

The court concluded that Achar’s submissions did not demonstrate either a likelihood of success on the merits or sufficiently serious questions, combined with a strongly favorable balance of hardships. It also determined that the Younger doctrine applied to the ongoing state proceedings. The court therefore denied Achar’s request for preliminary injunctive relief, identified as ECF 4. The court said it would issue an explanatory order later.

The court certified under 28 U.S.C. § 1915(a)(3) that any appeal from the order would not be taken in good faith and denied permission to appeal without paying filing fees. The clerk was directed to mail Achar a copy of the order and record service on the docket.