Fifth Circuit Holds Younger Doctrine Precludes Challenge to Louisiana Public Defender Fees
Fifth Circuit Holds Younger Doctrine Precludes Challenge to Louisiana Public Defender Fees
On April 16, 2012, the Fifth Circuit Court of Appeals held that the Younger abstention doctrine prohibits federal court challenges to Louisiana's public defender fees.
Steven Bice was arrested in New Orleans for public intoxication and public inhabitation, taken before the Municipal Court of New Orleans and qualified for representation by a public defender. La. R.S. § 15-168 provides for the funding of the public defender system, in part, by requiring all indigent criminal defendants who are convicted, plead guilty or plead nolo contendere to pay a $35 fee. Exonerated criminal defendants do not have to pay the fee. Bice filed a civil rights action pursuant to 42 U.S.C. § 1983 in federal court alleging that the fee arrangement violated his Sixth Amendment and Fourteenth Amendment rights by discouraging public defenders from seeking exoneration for their clients.
The district court dismissed the complaint after ruling that the Younger doctrine required abstention. Alternatively, the district court held that Bice had not stated a claim for which relief could be granted. Bice appealed.
The Fifth Circuit noted that the doctrine set out in Younger v. Harris, 401 U.S. 515 (1971), requires federal courts to decline to exercise jurisdiction if: "(1) the federal proceeding would interfere with an 'ongoing state judicial proceeding;' (2) the state has an important interest in regulating the subject matter of the claim; and (3) the plaintiff has 'an adequate opportunity in the state proceedings to raise constitutional challenges'" with a few exceptions. Neither Bice nor the state claimed that the exceptions applied or that the state did not have an interest in regulating the funding of public defenders.
The Fifth Circuit held that a ruling in Bice's favor would interfere with his state criminal prosecution and Bice could have raised the issue in municipal court, but had failed to do so. Thus, the Younger doctrine applied. It ignored Bice's argument that a municipal court ruling would not have afforded a statewide resolution because the case had not been certified as a class action and the municipal court could have given Bice relief for violations of his constitutional rights. Therefore, the court affirmed the district court's judgment. See: Bice v. Louisiana Public Defender Bd., 677 F.3d 712 (5th Cir. 2012).
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Related legal case
Bice v. Louisiana Public Defender Bd.
| Year | 2012 |
|---|---|
| Cite | 677 F.3d 712 (5th Cir. 2012) |
| Level | Court of Appeals |
| Conclusion | Bench Verdict |