Ashley v. Holcomb

Dist. Ct. erred in failing to grant defendants-Indiana state officials’ motion to dismiss on abstention grounds, plaintiffs’ (ten minors who are or were subject to Indiana CHINS proceedings) action, alleging that defendants violated their due process rights and requesting issuance of injunction with respect to how state investigates child welfare matters prior to CHINS proceedings, when state may or must initiate CHINS proceedings, and what relief state may or must pursue in CHINS court. Dismissal on abstention grounds was required, where record showed that relief sought by plaintiffs currently in CHINS system could be provided in CHINS proceedings, and plaintiffs failed to identify what relief options are open to federal court, but closed to CHINS court. Moreover, it is improper for federal courts to issue injunction requiring state officials to comply with state law.