In 2013 the LA County Superior Court, in response to substantial budget reductions during the recession, implemented various cost-saving measures, including the closure of a number of courthouses, layoffs of court staff, etc. The plan also included the “consolidation” of unlawful detainer cases, formerly heard in 26 courthouses throughout the county, into 5 “hub” courthouses, which would require low-income and disabled tenants residing, for example, in the San Fernando Valley, to travel to Santa Monica to litigate their evictions.
LSNC’s sister LSC programs, Neighborhood Legal Services of LA County and Legal Aid Foundation of Los Angeles, along with the Western Center and several disability rights groups, sued the LA courts in federal district court over this last provision, alleging that the court closures had a disproportionate and unlawful discriminatory impact on low income persons, minorities, and persons with disabilities.
Although the county did not initially even brief the issue, the federal district court dismissed the action on the grounds that it should “abstain” from hearing the case, invoking a seldom-used doctrine where federal courts may avoid exercising jurisdiction in cases where the remedy might entail “heavy federal interference” into the operation or management of a state court system.
On appeal, the Ninth Circuit affirms the dismissal based on abstention. It seems difficult to imagine how, in light of the court’s opinion, future plaintiffs alleging any institutional illegal or unconstitutional conduct by a state court will avoid a similar dismissal on abstention grounds.