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Miller-Williams v. Howard

United States Court of Appeals, Seventh Circuit
Mar 21, 2022
No. 21-2412 (7th Cir. Mar. 21, 2022)

Opinion

21-2412

03-21-2022

HELENE-TONIQUE LAURENT MILLER-WILLIAMS, Plaintiff-Appellant, v. CAROL M. HOWARD, et al., Defendants-Appellees.


NONPRECEDENTIAL DISPOSITION

Submitted March 18, 2022

We have agreed to decide the case without oral argument because the briefs and record adequately present the facts and legal arguments, and oral argument would not significantly aid the court. Fed. R. App. P. 34(a)(2)(C).

Appeal from the United States District Court for the Northern District of Illinois, Eastern Division. No. 1:20-cv-7437 Robert M. Dow, Jr., Judge.

Before MICHAEL S. KANNE, Circuit Judge, DAVID F. HAMILTON, Circuit Judge, MICHAEL B. BRENNAN, Circuit Judge

ORDER

Helene-Tonique Laurent Miller-Williams filed a civil lawsuit in the Circuit Court of Cook County, alleging that criminal charges pending against her in the same court violated her civil rights. See 42 U.S.C. § 1983. After the defendants removed the case to 1 federal court, the district court granted their motion to stay the case under the abstention doctrine set forth in Younger v. Harris, 401 U.S. 37, 41 (1971). The district court explained that allowing Miller-Williams to proceed with the federal civil case while the state criminal case was still pending might interfere with the parties' ability to litigate both cases.

Miller-Williams generally contests the district court's ruling, urging that her claims should move forward. But she does not address the district court's reasoning or the stay. See Fed. R. App. P. 28(a)(8)(A) (appellate brief must contain the appellant's "contentions and reasons for them, with citation to the authorities and parts of the record on which the appellant relies"). Regardless, the district court was correct to stay the case under Younger. Federal courts must refrain from taking jurisdiction over federal claims that risk disturbing ongoing state-court proceedings. See Younger, 401 U.S. at 41; J.B. v. Woodard, 997 F.3d 714, 722 (7th Cir. 2021). That is the case here. Miller-Williams's civil claims-albeit murky-arise from the same events that underlie the Illinois criminal charges, so any resolution of those claims in federal court could undermine the state court's proceedings. Gakuba v. O'Brien, 711 F.3d 751, 753 (7th Cir. 2013). No exceptions to the Younger abstention principles apply here.

AFFIRMED 2


Summaries of

Miller-Williams v. Howard

United States Court of Appeals, Seventh Circuit
Mar 21, 2022
No. 21-2412 (7th Cir. Mar. 21, 2022)
Case details for

Miller-Williams v. Howard

Case Details

Full title:HELENE-TONIQUE LAURENT MILLER-WILLIAMS, Plaintiff-Appellant, v. CAROL M…

Court:United States Court of Appeals, Seventh Circuit

Date published: Mar 21, 2022

Citations

No. 21-2412 (7th Cir. Mar. 21, 2022)

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