Tony Alamo Christian Ministries, et al. v. Selig, et al., No. 10-1424 (8th Cir. 2012)
Annotate this CaseIn an appeal from the district court's dismissal of a 42 U.S.C. 1983 action on grounds of standing and Younger v. Harris abstention, plaintiff argued that it had standing to assert various constitutional claims and that the district court also erred in abstaining in deference to the pending state-court actions regarding whether the minor children of the members of the church were neglected or abused. Defendants contended that the district court relied on abstention only with respect to the individual plaintiffs and that the church did not have standing to assert claims alleging a deprivation of its own federal rights much less those of its individual members. The court agreed that the district court applied abstention with respect to individual plaintiffs, and that it dismissed the church solely for lack of standing. Without reaching the question of standing at the pleading stage, however, the court affirmed because the court's analysis of Younger abstention with respect to the two individual plaintiffs was equally applicable to the church.
Court Description: Civil case - civil rights. Even if the Tony Alamo Christian Ministries has standing, the district court should have dismissed its claims based on Younger abstention principles as all of the Younger factors were met and the Ministries' interests were sufficiently intertwined with the individual members to warrant extension of Younger to the Ministries.
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