Whether Younger abstention requires a state administrative proceeding to be 'judicial in nature' and whether state administrative proceedings creating procedural barriers to federal civil rights claims are unconstitutional

No question identified. : APPLICATION TO EXTEND TIME TO FILE PETITION FOR WRIT OF CERTIORARI This Application is made to the Honorable Elena Kagan, as Circuit Justice for the United States Court of Appeals for the Ninth Circuit, see $.CtR. 30.3. Pursuant to this Court's Rules 13.5, 22, and 30.2, Pro Se Petitioner Peyman Roshan (“Roshan”) respectfully requests that the time to file his Petition for Writ of Certiorari in this matter be extended for 60 days up to and including October 17, 2025. The Court of Appeals published its opinion on March 11, 2025, Ninth Circuit Docket Number (“Dkt.”) 63; and denied Roshan’s petitions for rehearing and rehearing en banc on May 20, 2025, Dkt. 160. Absent an extension of time, the Petition for Writ of Certiorari would be due on July 19, 2025 which is more than ten days before this Application is filed. See S.CtR. 13.5 and 30.2. This Court has jurisdiction over the judgment under 28 U.S.C. 1254(1). Background This appeal presents questions of exceptional importance meriting review as, for one, questions of intra-circuit and inter-circuit conflict, specifically, the “judicial in nature” consideration for Younger abstention is evaluated? In Seattle Pacific University v. Ferguson, 104 F Ath 50 (9th Cir. 2024)(“SPU”), the Ninth Circuit acknowledged that for an administrative proceeding to be covered by Younger abstention, “the Supreme Court's guidance [is] that the proceeding must be "judicial in nature." SPU at 64. That panel also acknowledged that “San Jose Silicon Valley Chamber of Com. Pol. Action Comm. v. City of San Jose, 546 F.3d 1087, 1092 (9th Cir. 2008) abrogated on other grounds by Sprint Commc'ns, 571 U.S. 69, 134 S.Ct. 584, 187 L.Ed.2d 505.” Id. This issue was directly argued to the Court of Appeals; however the panel refused to recognize the above-referenced language from SPU and indeed refused to discuss the question of “judicial in nature” at all. It followed the example of a line of Ninth Circuit cases that refuse to discuss this requirement. An example of intentional intra-circuit split, which allows Courts to pick either the Baffert/San Jose/Roshan line of authority, Baffert v. Cal. Horse Racing Bd., 332 F.3d 613 (9th Cir. 2003), San Jose Silicon Valley Chamber of Com. Pol. Action Comm. v. City of San Jose, 546 F.3d 1087 (9th Cir. 2008), and Roshan vy. McCauley, 130 F.4th 780 (2025) (9"" Cir. 2025); or the Ohio Civil Rights U line, Ohio CR. Comm'n v. Dayton Christian Schs., Inc., 477 U.S. 619 (1986), New Orleans Pub. Serv., Inc. v. Council of New Orleans (“NOPST’), 491 U.S. 350 (1989), Sprint Commc'ns, Inc. v. Jacobs, 571 U.S. 69 (2013), and Seattle Pacific University v. Ferguson, 104 F.4th 50 (9th 2024)(“SPU”). Another question is whether under Williams v. Reed, 145 S. Ct. 465 (2025), the California State administrative proceedings, including those by the California Department of Real Estate exclusively reciprocally based on those by the California State Bar, are unconstitutional for creating procedura! barrier to obtaining relief in state court under 42 U.S.C. §1983. Reasons Justifying An Extension 1. Roshan was represented by counsel until oral argument below. He now, however, appears Pro Se. The complexity of the issues require the additional requested time for Roshan to prepare the Petition. 2. Due to health concerns of a family member, Roshan has scheduled a trip overseas between July 3, 2025 and July 19, 2025, at which time Roshan will be unavailable to prepare. 3. These issues are being honed and presented to multiple federal courts below; and it is presently unknown whether any of those Courts will moot this appeal. 4. Respondents will not be prejudiced as, in any event, Roshan’s Petition will be addressed by this Court in its subsequent term. Conclusion Roshan respectfully requests the time to file a writ of certiorari in the above captioned matter be extended 60 days to and including October 17, 2025. Dated this 13" day of June, 2025. Respectfully submitted: Peym