The Ninth Circuit issued two constitionally-based decisions today. First, in Gospel Missions v. City of Los Angeles, the court rejected facial First Amendment vagueness and overbreadth challenges to Los Angeles ordinances regulating the solicitation of charitable donations. Second, in M & A Gabaee v. The Community Redevelopment Agency, the court ruled that Younger absention applies when the parallel state court proceeding has begun but has "not yet reached proceedings of substance on the merits of the case." The court rejected the federal court plaintiff's contrary argument, noting that it "contradicts the whole purpose and tenor of the Supreme Court's holdings in Younger and Hicks."
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