No. 25-413

Jean Dominique Morancy, Father of L.M., a Minor v. Sabrina Alex Salomon, et al.

Lower Court: Eleventh Circuit
Docketed: 2025-10-06
Status: Denied
Type: Paid
Response Waived
Tags: appellate-review civil-rights-injunction due-process merits-inquiry procedural-standard younger-abstention
Key Terms:
SocialSecurity DueProcess JusticiabilityDoctri
Latest Conference: 2025-12-05
Question Presented (from Petition)

1. Whether Munaf v. Geren, 553 U.S. 674 (2008)
requirement that courts consider the underlying
merits—not merely jurisdictional questions—before
abstaining applies to civil rights injunctions under
Younger, and whether the lower courts' failure to
conduct any substantive merits inquiry violated this
precedent.

2. Whether a federal court of appeals, reviewing a
district court's application of the Younger v. Harris,
401 U.S. 37 (1971), abstention doctrine, may in the
first instance make its own factual findings on the
Middlesex County Ethics Committee v. Garden State
Bar Ass'n, 457 U.S. 428 (1982), factors—rather than
remanding for the district court to resolve disputed
facts—consistent with the requirements of due
process, Federal Rule of Civil Procedure 52(a), and
this Court's precedents limiting appellate fact-finding.

3. Whether the interplay between Younger abstention
and Federal Rules of Civil Procedure 15 and 16
requires that abstention be analyzed prior to court-
approved amendments, such that subsequent
refinements to a complaint do not trigger renewed
abstention review, thereby preventing procedural
confusion and ensuring consistent enforcement of civil
rights claims nationwide.

4. Whether the Eleventh Circuit erred in affirming
denial of a preliminary injunction through application
of a rigid, sequential "likelihood of success"
standard—contrary to other circuits' flexible/sliding-
scale approaches—thus deepening a circuit split in the
wake of Winter v. NRDC, impeding fair and equitable
relief in public law controversies.

Question Presented (AI Summary)

Whether Munaf v. Geren requirement that courts consider underlying merits before abstaining applies to civil rights injunctions under Younger, and whether lower courts' failure to conduct substantive merits inquiry violated precedent

Docket Entries

2025-12-08
Petition DENIED.
2025-11-18
DISTRIBUTED for Conference of 12/5/2025.
2025-11-04
Waiver of Sabrina A. Salomon, et al. of right to respond submitted.
2025-11-04
Waiver of right of respondent Sabrina A. Salomon, et al. to respond filed.
2025-09-21
Petition for a writ of certiorari filed. (Response due November 5, 2025)

Attorneys

Jean Dominique Morancy
Jean Dominique Morancy — Petitioner
Sabrina A. Salomon, et al.
Nicholas A. ShanninShannin Law Firm, P.A., Respondent