Clark Mershon Paul Mershon Gary Mershon v. Harold Kyser, Individually and in His Official Capacity as Prosecuting Attorney of Bates County, Missouri 64730 Hugh Jenkins, Individually and in His Official Capacity as Assistant Prosecuting Attorney of Bates County, Missouri 64730 Missouri Farmers Association, Inc., Brian Griffith William R. Beasley
Docket: 88-1141
Court: Court of Appeals for the Eighth Circuit; July 21, 1988; Federal Appellate Court
Clark, Paul, and Gary Mershon appeal the District Court's denial of their motions for a temporary restraining order and preliminary injunction against ongoing state criminal prosecutions. They argue that the court failed to apply the "bad-faith or harassment" exception to the Younger abstention doctrine. The Mershons had entered a promissory note with Missouri Farmers Association, Inc. (MFA), which subsequently filed a civil suit against them for owed money. Concurrently, MFA's employee filed a criminal complaint accusing the Mershons of defrauding a secured creditor. The Mershons counterclaimed in the civil suit, alleging MFA breached its obligations. Following the filing of criminal charges, the Mershons sued the Bates County prosecuting attorneys and MFA in federal court, claiming their constitutional rights were violated and that the criminal proceedings were initiated in bad faith to coerce them. Despite their claims of imminent and irreparable harm from the criminal prosecutions, the District Court ruled that their allegations did not sufficiently meet the criteria to overcome the Younger abstention doctrine, which generally prohibits federal intervention in state criminal matters unless exceptional circumstances exist. The Eighth Circuit Court of Appeals upheld the District Court's decision, affirming that the Mershons' constitutional rights were not sufficiently implicated to justify federal intervention under the Younger doctrine.