Geier, et al v. Missouri Ethics Commission, et al, No. 12-3853 (8th Cir. 2013)
Annotate this CasePlaintiff filed this suit in federal court against the Commission, seeking to enjoin a state enforcement proceeding. The district court abstained under the Younger doctrine and subsequently denied plaintiff's motion to amend its complaint as moot, having declined jurisdiction over the case. The court concluded that, even assuming the action was not completely dismissed until the district court filed its order, any error was harmless because plaintiff's proposed amendment to its complaint was futile. Plaintiff failed to carry its burden of proving that it could not adequately raise its constitutional issues in Missouri's administrative proceedings or courts, nor could it meet the narrow exception recognized by Younger. Therefore, the court affirmed the district court's decision to abstain.
Court Description: Civil case - Injunctions. Where the Missouri Ethics Commission had brought an enforcement action against plaintiff and a political action committee for failure to file ongoing reports and other documentation, the district court did not err in abstaining from plaintiffs' injunction action on the ground the state proceedings, through the administrative and appellate process, provided an adequate forum for plaintiffs to raise constitutional issues; district court did not err in denying plaintiffs' motion to amend their complaint as the matter had been dismissed; even if the action had not been completely dismissed, any error in denying the motion to amend was harmless as the proposed amendment was futile.
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