David Meador v. John Paulson

David Meador appeals the dismissal of his 42 U.S.C. § 1985 action against a state prosecutor and state court judge. We conclude that the district court 1 did not abuse its discretion in electing to abstain under Younger v. Harris, 401 U.S. 37, 91 S.Ct. 746, 27 L.Ed.2d 669 (1971), because at the time of the court’s order, a state criminal proceeding against Meador was ongoing; the proceeding implicated the important state interest of enforcing its criminal laws; and Meador can (and did) raise his constitutional claim in that proceeding. See Yamaha Motor Corp., U.S.A. v. Stroud, 179 F.3d 598, 602 (8th Cir. 1999) (standard of review); Norwood v. Dickey, 409 F.3d 901, 903 (8th Cir. 2005) (factors warranting abstention). We reject Mea-dor’s arguments that an exception to Younger applied, or that the district court improperly applied a heightened standard of review to his pro se complaint. Accordingly, we affirm. See 8th Cir. R. 47B.