Sanai v. Kruger

Background

Cyrus Sanai brought this federal action under 42 U.S.C. § 1983 and sought declaratory and injunctive relief against justices of the California Supreme Court. His claims concerned ongoing California State Bar disciplinary proceedings. The court previously dismissed the action under Younger abstention, a doctrine that generally requires federal courts to refrain from interfering with certain ongoing state proceedings, and denied the pending motions as moot.

Sanai moved under Federal Rules of Civil Procedure 59(e) and 60(b) to alter or set aside the judgment. He argued that the court wrongly found that the state proceedings gave him an adequate opportunity to raise federal constitutional claims, failed to recognize alleged bias by a State Bar Court judge, and relied on outdated precedent. He also argued that the court violated due process by dismissing his complaint without notice and should have dismissed the claims without prejudice. Sanai separately sought an injunction pending appeal.

Motion to Alter or Amend Judgment

The court treated Sanai’s request under Rule 59(e) because he filed it within 28 days after judgment. The court rejected his arguments concerning the third requirement for Younger abstention, holding that existing Ninth Circuit authority supported the conclusion that California’s attorney-discipline proceedings provide an adequate opportunity to present federal constitutional claims. The court also rejected Sanai’s argument that alleged actual bias prevented Younger abstention. It said his allegations did not overcome the presumption of honesty and integrity afforded to adjudicators and did not resemble the extreme facts in Caperton v. A.T. Massey Coal Co. The court further concluded that Caperton had not eliminated that presumption.

The court agreed with Sanai only that the dismissal should have been without prejudice. It amended the order and corresponding judgment to specify that the dismissal was without prejudice pursuant to Younger. The court otherwise denied Sanai’s motion to alter or amend judgment.

Motion for Injunction Pending Appeal

The court evaluated the request under the standard for a preliminary injunction. That standard asks whether the movant is likely to succeed on the merits, likely to suffer irreparable harm without relief, supported by the balance of equities, and advancing the public interest.

The court concluded that Sanai had not shown a likelihood of success because binding authority held that California’s attorney-discipline proceedings provide attorneys with more than constitutionally sufficient procedural due process. It also found no irreparable harm. Sanai’s claimed lost fees, including an alleged $55,000 in fees from two matters, were monetary injuries, and his complaint did not seek damages. The court further concluded that the balance of equities and public interest did not favor an injunction because interfering with the state disciplinary process would impede, rather than advance, the public interest.

Disposition

The court granted in part Sanai’s motion to alter or amend judgment by changing the dismissal to without prejudice, otherwise denied that motion, and denied Sanai’s motion for an injunction pending appeal.