Summary
The United States District Court for the District of Oregon remands a removed state-court stalking protective-order proceeding. The court holds that the plaintiff’s request for a stalking order does not arise under federal law under the well-pleaded complaint rule, and it also notes the domestic-relations exception and Younger abstention. The court concludes that it lacks subject-matter jurisdiction and remands the action to state court.
Court
United States District Court for the District of Oregon
Jurisdiction
United States District Court for the District of Oregon
Decision date
February 11, 2026
Docket number
6:26-cv-237-MC
Disposition
remanded
Questions Presented
- Whether the state-court stalking-protective-order proceeding arose under federal law so as to support federal-question jurisdiction under 28 U.S.C. § 1331.
- Whether the federal court could exercise jurisdiction over the domestic-relations stalking proceeding despite the domestic-relations exception to federal jurisdiction.
- Whether Younger abstention required the federal court to refrain from interfering with the ongoing state-court proceeding.
- Whether the case had to be remanded under 28 U.S.C. § 1447(c) because removal was improper and the federal court lacked subject-matter jurisdiction.
Holdings
- The proceeding did not arise under federal law because the plaintiff's requested stalking order did not present federal constitutional rights as an element or seek relief under federal law.
- The federal court lacked jurisdiction over the stalking case involving domestic relations because federal courts are generally prohibited from interfering in domestic-relations matters.
- Younger abstention applied because the state proceeding was ongoing, implicated important state interests, and provided an adequate forum for raising federal questions.
- The action had to be remanded to state court because the federal court clearly lacked subject-matter jurisdiction and the defendant failed to establish that removal was proper.
Court Document
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