Sprint-Gatekeeping Reinforced: Domestic-Relations Suits Alone Do Not Trigger Younger Abstention – A Commentary on Bellinsky v. Galan (10th Cir. 2025)

1. Introduction

In Bellinsky v. Galan, the United States Court of Appeals for the Tenth Circuit addressed the dismissal of two civil-rights actions brought by Rabbi Jacob Bellinsky against his former wife, her associates, state judges, prosecutors, and the State of Colorado. The district court had abstained from exercising jurisdiction under Younger v. Harris and, in part, dismissed under the Rooker-Feldman doctrine. The Court of Appeals reversed, clarifying that after the Supreme Court’s decision in Sprint Communications, Inc. v. Jacobs, a federal court must first determine whether the underlying state proceeding fits within one of three exclusive Sprint categories before invoking Younger abstention. Simply put, a domestic-relations custody action is not automatically such a category.

Beyond the abstention question, the Tenth Circuit also:

• Rejected the application of Rooker-Feldman because no final adverse state judgment was being attacked.
• Affirmed the district court’s refusal to recuse and its ruling that the Colorado Attorney General could represent state employees sued in their individual capacities.
• Remanded both cases for further proceedings, reviving Rabbi Bellinsky’s civil-rights claims.

2. Summary of the Judgment

The appellate panel (Tymkovich, Bacharach, and Federico, JJ.) issued a published Order and Judgment that:

1. Reversed the district court’s dismissal of Civil Action Nos. 23-cv-3163 and 23-cv-3461.
2. Held that the district court misapplied Younger by failing to determine whether ongoing state domestic-relations and criminal proceedings fell within any Sprint category.
3. Determined that Rooker-Feldman did not bar the federal suits because the plaintiff sought damages for alleged constitutional violations rather than modification of a state judgment, and because no final adverse judgment existed when he filed.
4. Found no abuse of discretion in denying judicial recusal and upheld representation by the Colorado Attorney General for individual state defendants.
5. Granted the plaintiff in-forma-pauperis status on appeal and denied all other pending motions.

3. Analysis

3.1 Precedents Cited and Their Influence

• Younger v. Harris, 401 U.S. 37 (1971)
  Classic abstention doctrine, counseling federal courts to refrain from interfering with certain state proceedings. The district court relied on it, but the Tenth Circuit clarified that post-Sprint its reach is narrower.
• Sprint Communications, Inc. v. Jacobs, 571 U.S. 69 (2013)
  Identifies three and only three categories in which Younger abstention may still apply: (1) ongoing state criminal prosecutions; (2) particular “civil enforcement” proceedings akin to criminal prosecutions; and (3) civil proceedings involving orders uniquely in furtherance of a state court’s ability to perform its judicial functions (e.g., contempt). The Tenth Circuit treated Sprint as a mandatory “gatekeeper.” Absent a finding that the state domestic-relations matter fit a Sprint category, abstention was error.
• Middlesex Cty. Ethics Comm’n v. Garden State Bar Ass’n, 457 U.S. 423 (1982)
  Provides the traditional three-factor test (ongoing proceeding, important state interest, adequate opportunity to raise federal issues) that is triggered only after a Sprint category is identified. The panel faulted the district court for applying Middlesex without first clearing the Sprint hurdle.
• Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) & District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983)
  Establish the jurisdictional bar preventing federal district courts from functioning as de facto appellate courts over state judgments. The Tenth Circuit limited the doctrine to cases seeking modification or reversal of a final state judgment—not present here.
• Morkel v. Davis, 513 F. App’x 724 (10th Cir. 2013)
  An unpublished pre-Sprint decision applied Younger to a domestic custody dispute by focusing solely on the three Middlesex factors. The district court relied heavily on this precedent, but the Tenth Circuit declared that reliance “misguided” because Sprint now controls.
• Covington v. Humphries, No. 24-1158, 2025 WL 1448661 (10th Cir. May 19, 2025)
  Reiterated that Sprint curtailed automatic abstention in domestic-relations matters. The panel used Covington to emphasize its reasoning.

3.2 The Court’s Legal Reasoning

The Tenth Circuit’s reasoning proceeded in distinct analytical stages:

1. Recusal — Applying an objective standard, the court found no reasonable basis to question impartiality. Adverse rulings alone do not establish bias (Liteky v. United States).
2. Authority of Colorado Attorney General — Interpreting Colo. Rev. Stat. § 24-31-101(1)(e) (now codified at § 24-31-101(m)), the court held that state employees are entitled to AG representation when the alleged conduct arises from official duties—even if sued “individually.”
3. Proper Framework for Younger Abstention
   • Step 1 (Sprint): Is the state proceeding (a) a criminal prosecution, (b) a quasi-criminal civil enforcement action, or (c) a proceeding involving orders necessary to judicial functions?
   • Step 2 (Middlesex): Only if Step 1 is satisfied do courts test for ongoing status, important state interest, and adequate forum.
   The district court leapt directly to Step 2, treating a child-custody dispute as inherently important to the state. Because it never identified a qualifying Sprint category, abstention was erroneous.
4. Rooker-Feldman Limitations — The plaintiff sought damages, not a vacatur of state orders. No final adverse judgment existed when he filed. Citing Nesses v. Shepard and Riehm v. Engelking, the panel stressed that corruption-based § 1983 claims do not implicate Rooker-Feldman when they attack conduct rather than the judgment itself.

3.3 Potential Impact on Future Cases

The decision is poised to have a substantial ripple effect, particularly within the Tenth Circuit:

• Domestic-Relations Litigants
  Plaintiffs alleging constitutional violations in custody or divorce contexts will face a lower abstention hurdle. District courts must conduct the Sprint analysis—no automatic abstention simply because “family law” is involved.
• District Court Practice
  Courts must expressly identify the Sprint category before invoking Younger. Failure to do so now constitutes reversible error.
• Scope of Rooker-Feldman
  Reinforces the doctrine’s narrowness: damages actions alleging corrupt processes are typically outside its reach unless the plaintiff explicitly seeks to undo a final state judgment.
• State Representation Rules
  Confirms the Colorado Attorney General’s statutory authority to represent state officers sued in their individual capacity, an issue that arises frequently in § 1983 litigation.
• Recusal Standards
  Reiterates that displeasure with rulings does not equal bias, discouraging tactical recusal motions.

4. Complex Concepts Simplified

• Younger Abstention: A doctrine that prevents federal courts from interfering in certain state proceedings. Think of it as a federal court hitting the “pause” button to respect state processes.
• Sprint Categories: The Supreme Court’s “special list” of situations where the pause button may be used. If a state proceeding is not on the list, the federal court keeps going.
• Middlesex Factors: The traditional three-question checklist (ongoing, important state interest, adequate forum). Today it is asked only after the Sprint gate is unlocked.
• Rooker-Feldman Doctrine: A rule that stops lower federal courts from acting like appellate courts over state-court decisions. It applies only when the plaintiff wants the federal court to overturn a final state judgment.
• Recusal: The process of a judge stepping aside. It is warranted when an objective observer would doubt the judge’s fairness, not merely when one party is unhappy with rulings.

5. Conclusion

Bellinsky v. Galan cements an important procedural checkpoint in the Tenth Circuit’s abstention jurisprudence: a federal court may abstain under Younger only after it verifies that the state proceeding belongs to one of the limited Sprint categories. Domestic-relations matters, despite their traditional importance to the states, are not automatically within those categories. In tandem, the ruling confines Rooker-Feldman to its rightful, narrow domain and reaffirms objective standards for judicial recusal and state-officer representation. Litigants and courts alike must now grapple with a clarified roadmap—one that prioritizes federal-forum access unless a clearly delineated abstention path exists.