Winn v. Cook, 2019 WL 72073332 (10th Cir. December 23, 2019) (OK): Winn filed a habeas petition under 28 U.S.C. § 2241. He alleged that a jury trial waiver he signed was invalid and asked the district court to order the state court to hold a jury trial. The panel held that Younger v. Harris, 401 U.S. 37 (1971) precluded federal intervention. Since the criminal proceedings still were ongoing and the state court already had held an evidentiary hearing on Winn’s claim that his waiver was involuntary, there was an adequate state forum to hear his claims. Besides, state criminal proceedings traditionally are areas primarily of state concern. Winn did not meet any of the Younger exceptions either. Even if his jury waiver remained in effect, he would not suffer "irreparable injury" because the "injury" still can be corrected by the state appellate court.