Opinion

Adkins

Court
District Court, W.D. Missouri
Filed
Feb 28, 2026
Cited by
0 cases
Authority
More cited than 39.0%

Summarizing the Supreme Court’s decision in Younger v. Harris, 401 U.S. 37 (1971)

How later courts described this case

  • Summarizing the Supreme Court’s decision in Younger v. Harris, 401 U.S. 37 (1971)

Written by the judges who cited it.

The opinion

IN THE UNITED STATES DISTRICT COURT FOR THE

WESTERN DISTRICT OF MISSOURI

ST. JOSEPH DIVISION

BENJAMIN D. WILLIAMS and )

NICOLE M. KOCH, )

)

Plaintiffs, )

v. ) No. 26-06037-CV-SJ-BP

)

DAREN ADKINS, et al., )

)

Defendants. )

ORDER (1) DENYING MOTION FOR TEMPORARY RESTRAINING ORDER AND

(2) DIRECTING PLAINTIFFS TO SHOW CAUSE WHY CERTAIN DOCUMENTS

SHOULD REMAIN SEALED

Plaintiffs Benjamin Williams and Nicole Koch, who are proceeding pro se, have filed a

Complaint alleging violations of their civil rights. Among the Defendants are state judges, police

officers, individuals working for Children’s Services, at least one Guardian ad Litem, the City of

Chillicothe, and Livingston County. Now pending is Plaintiffs’ Motion for Temporary Restraining

Order, (“TRO”), which is DENIED.

The nature of Plaintiffs’ claims is not entirely clear, but they refer to (1) prior criminal

cases filed against them in Livingston County and (2) upcoming hearings in juvenile court and

probate court in Livingston County. The Court takes judicial notice of the criminal cases; the

information has been obtained from Missouri’s online system for accessing court records

(Case.Net).1

In June 2023, Plaintiffs were charged with, among other things, four counts of first degree

endangering the welfare of a child. In September 2023, Williams pleaded guilty to one count of

first degree endangering the welfare of a child; the other counts were dismissed. In November

1 The case numbers are 23LV-CR00171-01 and 23LV-CR00172-01

2023, he was sentenced to seven years in prison, but execution of the sentence was suspended and

he was placed on probation for five years. Koch pleaded guilty to the same charge in December

2023 (with the other charges dismissed); in March 2024 imposition of sentence was suspended

and she was placed on probation for five years.

In both their Complaint and their Motion for TRO, Plaintiffs refer to upcoming hearings in

juvenile court (set for March 2, 2026) and probate court (set for March 9, 2026). Those cases

cannot be found on Case.Net, likely because they involve minor children (and juvenile cases are

frequently not publicly accessible in any event). The Amended Complaint describes the case on

probate court as a guardianship proceeding. These and other allegations demonstrate those

hearings are related to Plaintiffs’ criminal cases, likely because they involve the child(ren)

involved in those prior cases. This connection is further established by Plaintiffs’ explanation for

some of the relief they seek; among other things, they ask the Court to enjoin those hearings and

bar the use of any evidence obtained from the search warrants that led to their criminal charges

because they believe those warrants should not have been issued. They also ask the Court to order

that different judges be assigned to hear those cases.

Plaintiffs’ Motion is denied because it seeks relief the Court cannot grant. Federal courts

generally cannot enjoin (1) state criminal proceedings or (2) civil proceedings that are similar to

criminal prosecutions. See Sprint Commc’ns, Inc. v. Jacobs, 571 U.S. 69, 72-73 (2013)

(Summarizing the Supreme Court’s decision in Younger v. Harris, 401 U.S. 37 (1971)).2 Juvenile

court proceedings, including those addressing parental rights, are subject to this prohibition. E.g.,

Sprint Commc’ns, 571 U.S. at 79 (citing Moore v. Sims, 442 U.S. 415 419-20 (1979)); Brown v.

2 Younger represents a limit on a federal court’s power, so the Court of Appeals has approved decisions by district

courts raising Younger abstention even when the parties did not. E.g., Ashford v. Office for Counsel for Discipline,

805 Fed. App’x 446 (8th Cir. 2020); Curd v. City of Searcy, AR, 739 Fed. App’x 359 (8th Cir. 2018); Geier v. Missouri

Ethics Comm’n, 715 F.3d 674 (8th Cir. 2013).

Arkansas Dep’t of Human Servs., 452 Fed. App’x 690, 692 (8th Cir. 2011); Amerson v. State of

Iowa, 94 F.3d 510, 512 (8th Cir. 1996). Younger also forbids a federal court from enjoining “orders

that are uniquely in furtherance of the state courts’ ability to perform their judicial functions.”

Sprint Commc’ns, 571 U.S. at 73. This category of cases and orders focuses on the “institutional”

interest of allowing state courts to operate; examples include orders related to contempt

proceedings and posting bond pending appeal. 375 Slane Chapel Road, LLC v. Stone Cnty, MO,

53 F.4th 1122, 1127 (8th Cir. 2022). Here, Plaintiffs request an Order (1) enjoining whatever

orders or procedures resulted in the cases being assigned to the judges presiding over them and (2)

requiring the state courts to reassign the cases to different judges. They also ask the Court to issue

rulings regarding how those hearings should be conducted. Such directives would interfere with

the state courts’ ability to perform judicial function and are prohibited by Younger.

The relief sought by Plaintiffs’ Motion for TRO cannot be granted. Therefore, the Motion,

(Doc. 2), is DENIED.

In addition, the Court observes that Plaintiffs filed certain documents under seal;

specifically, (1) a copy of the search and arrest warrants (and documents related to them) and (2)

the Motion for TRO (to which the warrants and associated documents are attached). Plaintiffs did

not seek permission to have the documents filed under seal, and the Court’s review reveals no

reason for them to be sealed. Plaintiffs shall have 14 days to respond to this Order and explain

why these documents should remain sealed.

IT IS SO ORDERED.

/s/ Beth Phillips

BETH PHILLIPS, JUDGE

DATE: February 28, 2026 UNITED STATES DISTRICT COURT

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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