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CIVIL PRACTICE citing the younger Abstention Doctrine, the 9th U.S. Circuit Court of Appeals on June 6 said that a California federal court erred in deciding a case filed by championship horse trainer Bob Baffert contesting his suspension by state racing authorities, because the court lacked jurisdiction to do so. Baffert v. California Horse Racing Ass’n, No. 02-55858. California racing authorities suspended Baffert for 60 days after his horse, Nautical Look, tested positive for a banned substance. Baffert sued, arguing that, by destroying the samples for the test, the California Horse Racing Board violated his rights under 42 U.S.C. 1981. After a trial court held for Baffert, the board appealed, arguing that under the U.S. Supreme Court’s decision in Younger v. Harris, the trial court was without jurisdiction to make a ruling. The 9th Circuit agreed, ruling that Younger abstention deprived the trial court of its jurisdiction. The court held that this exception to mandatory federal jurisdiction applied because there was an ongoing state action dealing with important state interests, and that Baffert had the opportunity to raise his federal claims within the confines of the state action.

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