Tenth Abstains from Exercising Jurisdiction in Family Court Case

Chapman v. Oklahoma, --- F.3d ----, 2006 WL 3720258 (10th Cir. Dec. 19, 2006)

Inmate brought suit for himself and other inmates against Oklahoma’s family court system for constitutional violations arising out of its adjudications on non-custodial parent issues. 10th holds that Rooker-Feldman doctrine barring federal jurisdiction was not applicable in this case because the Plaintiff filed his suit before expiration of his state appeals process (he filed in OK state courts too), but Younger abstention doctrine applies. The 3 Younger abstention factors were present (ongoing state proceeding, important state interests, state is an adequate forum), and abstention from fed jurisdiction was therefore mandatory. Remanded for dismissal without prejudice.